THE U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 


PUBLIC HEALTH SERVICE 


CENTERS FOR DISEASE CONTROL AND PREVENTION 


NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH 


convenes the 


WORKING GROUP MEETING 


ADVISORY BOARD ON 


RADIATION AND WORKER HEALTH 


FERNALD
 

The verbatim transcript of the Working 


Group Meeting of the Advisory Board on Radiation and 


Worker Health held in Cincinnati, Ohio on August 8, 


2007. 


STEVEN RAY GREEN AND ASSOCIATES 

NATIONALLY CERTIFIED COURT REPORTERS 

404/733-6070 
2 

 6 

C O N T E N T S
 

August 8, 2007 


WELCOME AND OPENING COMMENTS 


DR. LEWIS WADE, DFO 


INTRODUCTION BY CHAIR 14 


FERNALD OVERVIEW 17 


MATRIX DISCUSSION: 51 


QUESTIONABLE INTEGRITY OF FLUOROPHOTOMETRIC URINALYSIS 


FAILURE TO MONITOR ALL PERSONNEL WITH POTENTIAL 


RADIONUCLIDE CONTAMINANTS IN RU, INADEQUATELY 


FLUOROPHOTOMETRIC URINALYSIS DATA 65 


DATA 111 

INTERNAL EXPOSURE TO URANIUM 129 


CONSIDERED 149 

K-65 DEFAULT MODEL 167 


RAC 1995 REPORT 179 


INTERNAL DOSE ESTIMATES FOR THORIUM 190 


RADIOLOGICAL THORIUM INCIDENTS 219 


THORIUM PRODUCTION 235 


RE-DRUMMING 236 

THORIUM INGESTION 242 


DATA INTEGRITY FOR AIR MONITORING 244 


MOBILE IN VIVO RADIATION MONITORING LAB 262 


WORKER SELECTION CRITERIA AND INFREQUENT USE MIVRML 290 


THORIUM LUNG COUNT DATA 294 


OTIB-0002 301 

PERSONNEL DOSIMETERS 311 


UNACCOUNTED DOSES TO EXTREMITIES 331 


SKIN/CLOTHING CONTAMINATION 340 


NEUTRON DOSES 352 


UNMONITORED FEMALE WORKERS 355 


ACTION ITEMS 368 


COURT REPORTER’S CERTIFICATE 
 389 
3 

TRANSCRIPT LEGEND
 

The following transcript contains quoted material. Such 


material is reproduced as read or spoken. 


In the following transcript: a dash (--) indicates 


an unintentional or purposeful interruption of a 


sentence. An ellipsis (. . .) indicates halting speech 


or an unfinished sentence in dialogue or omission(s) of 


word(s) when reading written material. 


-- (sic) denotes an incorrect usage or pronunciation 


of a word which is transcribed in its original form as 


reported. 


-- (phonetically) indicates a phonetic spelling of 


the word if no confirmation of the correct spelling is 


available. 


-- "uh-huh" represents an affirmative response, and 


"uh-uh" represents a negative response. 


-- "*" denotes a spelling based on phonetics, 


without reference available. 


-- (inaudible)/ (unintelligible) signifies speaker 


failure, usually failure to use a microphone. 

 

 

 

4

1 

2 

3 

P A R T I C I P A N T S 


(By Group, in Alphabetical Order) 


BOARD MEMBERS
 

ZIEMER, Paul L., Ph.D. 


Professor Emeritus 


School of Health Sciences 


Purdue University 


Lafayette, Indiana 


EXECUTIVE SECRETARY
 

WADE, Lewis, Ph.D. 


Senior Science Advisor 


National Institute for Occupational Safety and Health 


Centers for Disease Control and Prevention 


Washington, DC 


MEMBERSHIP
 

CLAWSON, Bradley 


Senior Operator, Nuclear Fuel Handling 


Idaho National Engineering & Environmental Laboratory 


GRIFFON, Mark A. 


President 


Creative Pollution Solutions, Inc. 


Salem, New Hampshire 


PRESLEY, Robert W. 


Special Projects Engineer 


BWXT Y12 National Security Complex 


Clinton, Tennessee 


SCHOFIELD, Phillip 


Los Alamos Project on Worker Safety 


Los Alamos, New Mexico 

5 

IDENTIFIED PARTICIPANTS
 

BALDRIDGE, SANDRA, PETITIONER 


BEATTY, EVERETT RAY, SR., SEC CO-PETITIONER 


BEHLING, HANS, SC&A 


CHEW, MELTON, CAI 


ELLIOTT, LARRY, NIOSH 


FAUST, LEO 


HILL, STEPHEN, CONG. CHABOT 


HINNEFELD, STUART, NIOSH 


HOFF, JENNIFER, ORAU 


HOWELL, EMILY, HHS 


JESSEN, KARIN, ORAU 


KENT, KAREN, ORAU 


KOTSCH, JEFF, DOL 


MAKHIJANI, ARJUN, SC&A 


MAURO, JOHN, SC&A 


MORRIS, ROBERT, CAI 


RICH, BRYCE L., CAI 


ROLFES, MARK, NIOSH 


SHARFI, MUTTY, ORAU 

6 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

P R O C E E D I N G S


 (8:00 a.m.) 

WELCOME AND OPENING COMMENTS
 

DR. LEWIS WADE, DFO


 DR. WADE: Hello, this is the work group 


conference room. This is Lew Wade. Is there 


anyone out there on the telephone this 


morning? 


 (no response) 


 DR. WADE: Anyone on the telephone? 


 (no response) 


 DR. WADE: It could be that there’ll be no 


one but us. Was John Mauro expected? 


DR. BEHLING: No, he’s not, but he did say 


he will be on the telephone. He’s probably 


going to join us a little later. 


 DR. WADE: Good morning all. This is the 


work group conference room, Lew Wade. John 


Mauro, are you out there? 


DR. MAURO (by Telephone): Yes, I am, Lew. 


 DR. WADE: Can you hear me? 


DR. MAURO (by Telephone): I hear you 


perfectly well. 


 DR. WADE: We’re going to do some 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

7 

introductions and maybe you could be our sound 


monitor. If anyone’s introduction is not 


clear to you just sort of shout out, and we’ll 


make the necessary physical adjustments. 


DR. MAURO (by Telephone): I’ll do that. 


 DR. WADE: Thank you. 


We’re just waiting for the court 


reporter to make several final adjustments, 


and then we will be ready to begin. It is 


hard to get good help anymore so we do with 


what we have. 


This is Lew Wade, and I have the 


privilege of serving as the designated federal 


official for the Advisory Board. And this is 


a meeting of a work group of the Advisory 


Board. This particular work group is looking 


at the Fernald site profile and SEC petition, 


so it’s looking at both. 


That work group is chaired by Brad 


Clawson, members Griffon, Ziemer, Presley and 


Schofield. All of the members of the work 


group are here around the table. 


Let me first ask if there are any 


other Board members who are on the telephone. 


Are there other Board members who are on the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

8 

telephone with us this morning? 


 (no response) 


 DR. WADE: Any other Board members? 


 (no response) 


 DR. WADE: Okay, well, we have five Board 


members present. That’s not a quorum, and 


that’s appropriate for a work group meeting. 


If we did have a quorum of the Board, we’d 


have to make adjustments. So we’re in good 


shape on that stead. 


What I’d like to do now is make some 


introductions. First, we’re honored to have 


in the room with us Stephen Hill who 


represents Congressman Chabot from the First 


District of Ohio. Stephen, thank you for 


being here, and we appreciate it. And if you 


have any questions or things to say during the 


proceedings, please let us know. We’re very 


much honored to have a representative of a 


congressman with us. 


What I do now is go through the 


introductions. The court reporter is up and 


functioning, and everything is working 


correctly, right? We’re going to do a little 


bit of adjustment for the court reporter. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

9 

Okay, now what I’ll do is go around 


the table, and ask everyone here in the room 


to introduce themselves. Then we’ll go on the 


telephone and we’ll ask for members of the 


NIOSH and ORAU teams to introduce themselves, 


then members of the SC&A team to introduce 


themselves, other federal employees who are on 


the phone, members of Congress or their 


representatives, petitioners, claimants, 


people who are expert with regard to the site, 


and then any others who would like to identify 


themselves. 


When Board members or NIOSH/ORAU team 


members or SC&A team members identify 


themselves, I would like you to very briefly 


address whether or not you have any conflict 


of interest relative to the Fernald site. 


Once we complete the introductions, we’ll talk 


a little bit about telephone courtesy, and 


then I’ll turn it over to the chairman who 


will begin the proceedings. 


Again, this is Lew Wade. I serve the 


Advisory Board. I am also an employee of 


NIOSH, and I have no conflicts relative to the 


Fernald site. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

10

 MR. PRESLEY: Robert Presley, working group 


member, and I have conflicts with the Fernald 


site. 


DR. ZIEMER: I’m Paul Ziemer, working group 


member, and I have no conflicts. 


MS. KENT: I’m Karen Kent, part of the ORAU 


dose reconstruction team, all with no 


conflicts. 


 MR. SHARFI: I’m Mutty Sharfi for the ORAU 


team, no personal conflicts. 


MS. HOFF: I’m Jennifer Hoff. I’m with the 


ORAU team, and I have no conflicts. 


DR. BEHLING: Hans Behling, SC&A, no 


conflict. 


MR. ROLFES: Mark Rolfes, NIOSH Health 


Physicist, no conflict of interest. 


MR. CHEW: Mel Chew, the ORAU team. I have 


no conflict with Fernald. 


 MS. JESSEN: Karin Jessen, O-R-A-U, no 

conflicts. 

MR. MORRIS: Robert Morris, O-R-A-U team, no 

conflicts. 

MR. GRIFFON: Mark Griffon, work group 


member, no conflict. 


MR. BEATTY: Ray Beatty, former worker. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

11

 MR. CLAWSON: Brad Clawson, working chair 


for Fernald, no conflict. 


MR. HINNIFELD: I’m Stu Hinnifeld from the 


NIOSH staff, and I do have a conflict or 


potential bias associated with Fernald that I 


worked in the Radiation Detection Department 


there. 


DR. MAKHIJANI: Arjun Makhijani, I declare I 


have a conflict that my work was cited in the 


SEC petition. 


MR. SCHOFIELD: Phil Schofield, working 


group member, no conflicts. 


MS. HOWELL: Emily Howell, HHS, no 


conflicts. 


 DR. WADE: Okay, let’s go out then to those 


on the telephone, and I’ll start with members 


of the NIOSH or ORAU team. Anyone 


representing NIOSH or the ORAU team on the 


telephone? 


 (no response) 


 DR. WADE: SC&A team? 


DR. MAURO (by Telephone): John Mauro, SC&A, 


no conflict. 


 DR. WADE: Other members of the SC&A team? 


 (no response) 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

12

 DR. WADE: Other federal employees who are 


participating by virtue of their employment? 


MR. KOTSCH (by Telephone): Jeff Kotsch, 


Department of Labor. 


 DR. WADE: Welcome, Jeff. 


Other federal employees? 


 (no response) 


 DR. WADE: Any other members of Congress or 


their representatives? 


(no response) 


 DR. WADE: Again, we’re honored to have 


Stephen Hill with us here in the room. 


Petitioners, claimants, those familiar 


with the Fernald site? 


 (no response) 


 DR. WADE: Is there anyone else on the call 


who’d like to be identified for the record? 


 (no response) 


 DR. WADE: I would say that the way the 


working groups have functioned if there are 


people with site expertise in the room, 


workers or representatives, you should feel 


free to comment as you would like. I think 


it’s important that as much knowledge be 


brought to the table as possible so consider 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

13 

yourself a part of these deliberations. 


By way of phone etiquette I’d each of 


you connected by the phone to remember that 


noise from your site can be very distracting 


so if you’re not speaking or are about the 


speak, mute your instrument if at all 


possible. When you do speak, speak into a 


handset. Don’t use a speaker phone. And be 


extremely mindful of background noise so that 


you don’t disrupt the ability of this group to 


use its time productively. 


We have one new addition to the table. 


If you could. 


MR. RICH: Bryce Rich with CAI. 


 DR. WADE: And do you have a conflict 


relative to the Fernald site, Bryce? 


MR. RICH: I do not. 


DR. MAURO (by Telephone): Lew, this is John 


Mauro. The last person that introduced 


himself I could not quite hear. 


MR. RICH: Bryce Rich. 


 DR. WADE: Did you hear Bryce? 


DR. MAURO (by Telephone): Yes, I did, thank 


you. Hi, Bryce. 


 DR. WADE: Bryce had just walked into the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

14 

room and hadn’t made his way fully to the 


table yet. But please, John, again, do us the 


service if we tend to fade, let us know. We 


would appreciate that. 


No more introductory materials. Brad, 


it’s yours. 


INTRODUCTION BY CHAIR


 MR. CLAWSON: I appreciate that for the fine 


introductions. First of all, this is my first 


working group so please forgive me on a lot of 


this stuff. I don’t know a lot of the 


etiquettes. But one of the things I wanted to 


start out with is I wanted to ask that Hans, 


being the SC&A person, have we looked at the 


petition that has been filed, and have we 


covered all of the petitioner’s issues with 


Fernald and with the paper that has been 


written? Have we covered all those? 


DR. BEHLING: Yeah, if you read the report, 


there is a section that is dedicated to 


addressing issues raised by the petitioner. 


And I believe I have addressed in different 


ways all of the issues that were raised by the 


petitioner. 


 MR. CLAWSON: Okay, I appreciate that. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

15 

Who wrote this matrix for NIOSH? 


MR. ROLFES: That would be myself as well as 


(inaudible) associates. 


 MR. CLAWSON: Okay, I wanted to get that. I 


did notice one thing right off the bat. I 


thought at this board, we were all to look to 


see if these were SEC issues. I didn’t 


realize that you guys would make these 


assumptions right off the front of this. But 


it was kind of interesting for me to be able 


to see that. But I guess what I’d like to be 


able to see right now is if you could kind of 


give us an overview of what Fernald did and 


kind of the timeframe that we are looking at 


if you could. 


 DR. WADE: Before you begin, is there anyone 


who needs a copy of the matrix? A hard copy 


of the matrix? 


DR. ZIEMER: What is the date on this 


matrix? We’ve gotten several versions. 


MR. ROLFES: August 3rd . Yes, this is just 


the matrix so this shouldn’t have, this should 


be the one and only that was sent out to the 


Advisory Board. 


 MR. PRESLEY: I got mine on the sixth, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

16 

August 6th is what date’s on mine, August 6th , 


at 11:18 p.m. 


MR. ROLFES: Yeah, the paper is dated the 


third, and the e-mail was sent out on the 


sixth. 


 DR. WADE: Just to follow up on a comment 


Brad made, in the Draft NIOSH Response column, 


NIOSH will occasionally say this is not an SEC 


issue. That’s NIOSH’s opinion. Board can do 


whatever it wishes with it obviously. 


DR. MAKHIJANI: Mark, where’s the date on 


the paper? 


MR. ROLFES: On the bottom left-hand corner. 


I don’t have a hard copy in front of me at the 


moment, but --


DR. MAKHIJANI: My copy doesn’t have a date. 


MR. ROLFES: Right here it says Matrix from 


Fernald SEC Issues, August 3rd . 


DR. MAKHIJANI: Can I have another hard copy 


because I’m not sure I have the latest 


version. 


MR. ROLFES: I just gave my last one out. I 


apologize. 


So there anything else before we 


begin, Brad, that you’d like to --

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

17

 MR. CLAWSON: No, not at this time. 


FERNALD OVERVIEW
 

MR. ROLFES: Well, I guess I will give you a 


brief overview of what Fernald did, and then 


give you an update on our changes to the 


technical basis document that we use for dose 


reconstruction. 


To be brief if you remember in the 


very beginning, I believe this document, the 


initial technical basis document, was dated 


from late 2003 or early 2004. And we had a 


big push to get some answers out to claimants 


in a timely manner. We wanted to get a 


technical basis document that we could use for 


making scientific decisions with claimant 


favorability incorporated. 


So we took as much information as we 


had at the time to assemble this technical 


basis document to cover as much as we could in 


the limited amount of time that we had. And 


so we realized that we didn’t incorporate 


everything at that time and these documents 


are living documents, and when we received 


public comments, we update the documents as 


well as when we receive additional reports and 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

18 

information. 


So we have begun working on the 


technical basis document as a result of the 


SEC evaluation and SEC evaluation process, I 


guess. I’d like to give you a brief update on 


the changes that are in progress to the 


Fernald technical basis document used for dose 


reconstructions. 


One of the first issues that we looked 


at was the ingot rider. We received a picture 


of an individual working, I believe, in Plant 


9 who was straddling a large uranium ingot. 


We realized that there was a possibility that 


some stampers experienced unmeasured full body 


and skin doses while straddling ingots during 


the stamping operations. So we took 


evaluation time, motion and frequency based on 


worker interviews, and we performed 


calculations to estimate dose rates that the 


worker was exposed to. 


We also took a look at neutron-tophoton ratios. We know that neutron dosimetry 


was not implemented due to the near absence of 


neutrons at Fernald. We had results of a 


neutron dose rate survey that were conducted 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

19 

in Building 4B where there were over 12,000 


drums of uranium hexafluoride present. Two 


percent of the drums contained enriched 


material. 


Now, keep in mind natural uranium is 


approximately .71 weight percent. So two 


percent of the drums were enriched to 1.25 


percent up to two percent. Twenty-three 


percent of the drums were enriched from 


natural up to 1.25 percent. And 75 percent of 


the drums contained natural or depleted 


uranium. The highest neutron dose rate that 


we observed was .089 millirem per hour. And 


it gave a calculated neutron-to-photon ration 


of less than 0.1. 


What we have in the technical basis 


document at this time is a neutron-to-photon 


ratio of 0.23, and so this report confirmed 


that what we have is claimant favorable for 


dose reconstructions. 


DR. MAKHIJANI: Mark, where was this dose 


rate measured? 


MR. ROLFES: Where was the dose rate 


measured? It was in Warehouse 4B. 


DR. ZIEMER: Surface of the drums or what? 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

20 

MR. ROLFES: There were multiple 


measurements taken. I’d have to take a look 


at the hard copy report to tell you the exact 


locations. 


DR. BEHLING: And how were these 


measurements made both for the neutrons and 


photons? Instruments? Using instruments? 


MR. ROLFES: I believe there were survey 


instruments. 


DR. BEHLING: And what source was used to 


calibrate those instruments? 


MR. ROLFES: Did you happen to take a look 

at that? 

MR. MORRIS: I didn’t. I don’t know the 

answer to that. It may be in the report. 


DR. BEHLING: Because a lot of problems I’ve 


seen is that they used polonium, beryllium or 


plutonium-beryllium sources and then measured 


neutrons that they were very different in 


their energy spectrum; and therefore --


MR. MORRIS: REM meters tend to over-respond 


in those regions and so the errors are to give 


you a higher neutron dose than a lower neutron 


dose. 


MR. GRIFFON: Just hold on one second. The 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

21 

report you’re referencing, is that available 


on the O drive? 


MR. MORRIS: Sure. 


MR. GRIFFON: It might be good just to, and 


as we go through the day I think I’m going to 


repeat that question. Let’s make these 


documents available so we have them. So we 


don’t at the end of the course --


MR. ROLFES: At this time it is not on the O 


drive. I will definitely make it available. 


MR. GRIFFON: Yeah, put it in our AB system 


so we can find it easily. 


MR. ROLFES: Sure, I certainly will. 


DR. ZIEMER: Robert -- and this is Ziemer --


what surveys did you say they were using for 


that? You said it was a REM meter. 


MR. MORRIS: I’m thinking it’s a Snoopy. 

DR. ZIEMER: Snoopy? Okay, fine. 

MR. MORRIS: I don’t know the model number 

off the top of my head on that. It may be in 


the report. 


MR. CHEW: Leo Faust actually did this work 


for us. 


DR. MAKHIJANI: Are there any neutron data 


for Building 7, Plant 7? 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

22 

MR. ROLFES: As far as personnel dosimetry 


or area monitoring? 


DR. MAKHIJANI: Any data at all. 


MR. ROLFES: I would have to take a look at 


the records. We do have neutron dosimetry 


results in HIS-20 from more recent years, I 


believe. However, given the near absence of 


neutrons based on the surveys that they 


conducted, they really didn’t see that many 


neutrons. And they basically took a look at 


them via observed exposure rates and 


determined that it was not something that 


would be detectable by a worker. 


DR. MAKHIJANI: Plant 7 operated only for 18 


months in the 1950s, and it had uranium 


hexafluoride so I don’t think, I don’t see how 


you can make the assumption then that there 


were negligible neutrons. 


MR. ROLFES: I’m sorry. I couldn’t hear all 


of what you said, Arjun. 


DR. MAKHIJANI: Plant 7 operated only for 18 


months in the 1950s, and they had uranium 


hexafluoride there. I don’t see how you can 


assume they had negligible neutrons. 


MR. ROLFES: That’s very possible. We’ll 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

23 

have to take a look into that since the work 


was similar to Portsmouth or Paducah. What we 


can do is evaluate the observed neutron-tophoton ratios there and possibly use that 


information in order to address unmonitored 


doses in the early days. 


DR. MAKHIJANI: Have you taken into account 


the criticism of neutron-to-photon ratio that 


happened in the Rocky Flats? 


MR. ROLFES: Fernald is a separate site, and 


I wouldn’t compare Fernald to Rocky Flats 


given that there was no plutonium production 


going on at Fernald. Fernald was a uranium 


facility. Their major goal was to produce 


depleted uranium targets for shipment to the 


Savannah River site and Hanford where they 


were irradiated in reactors to produce 


plutonium. There were also some smaller for 


thorium to produce thorium metal for shipment 


to several different reactors to produce U233. I don’t think it’s a credible comparison 


to take a look at the neutron doses from Rocky 


Flats and compare those to Fernald. 


MR. GRIFFON: Just the approach. 


DR. MAKHIJANI: That wasn’t the question. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

24 

But the question was there’s a method of using 


neutron-to-photon ratios in buildings and 


areas that were generally evaluated in the 


specific context of Rocky Flats not the 


specific ratios at Rocky Flats to be used some 


place else. And there were a lot of problems 


that -- and maybe they can be overcome in your 


analysis at Fernald, but the problems that 


were discovered, for instance, that building 


neutron-to-photon ratios may not apply to job 


types. There’ll be a lot of variation over 


time and over workstations. Those kinds of 


observations -- anyway, the --


MR. ROLFES: The bottom line that we draw is 


that we’re assigning, the bottom line that 


we’re doing in dose reconstructions which we 


feel is claimant favorable unless we have 


information that indicates to the contrary, 


we’re assigning a 0.23-to-one neutron-tophoton ratio for everyone that worked in, 


there’s a couple of plants. 


We can also take a look at Plant 7 


that operated for a short amount of time in 


the early 1950s. But in comparison to all the 


reports that we have seen, the neutron-to­
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

25 

photon ratios that we are assigning are 


claimant favorable in comparison to the 


observed measurements. 


DR. BEHLING: Let me also interrupt. In 


your original report the 0.23 N gamma ratio 


was defined in behalf of a single drum, and 


those were empirical measurements. Your 


revisiting of that issue involves another 


different study. In fact, in the original 


study that 0.23 was, in fact, the 95th
 

percentile value of the N gamma ratio. You’ve 


now looked at another study and looked at 


different measurements, I assume, and you’re 


sticking with the 0.23 N gamma ratio. Is that 


also the 95th percentile value? 


MR. ROLFES: I’m not certain. Is that 0.1 

or the .023? 

MR. MORRIS: The .23 is the 95th percentile. 

DR. BEHLING: Also in the second study? In 


the original it was in the 95th percentile 


value, and you said will be claimant favorable 


by assuming the 95th percentile value. This is 


a different study, the same value. In the 


second study was this value also defined as 


the 95th percentile value? 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

MR. MORRIS: No, it was the largest value. 

 MR. SHARFI: But your largest value is less 

than 0.1? 

MR. ROLFES: Right, exactly. So there’s 

0.089. 

 MR. SHARFI: Point 23 is still bounding 

versus the largest value on the new study. 


MR. ROLFES: Any other questions before I 


move on? 


MR. SCHOFIELD: How well do you know the 


characterization of this material? Is this an 


assumption or is this by actual analysis? 


MR. ROLFES: This is documented. This is 


documented information. The quantities of 


material, the green material. Two percent of 


the drums were enriched between 1.25 percent 


and two percent. Twenty-three percent of the 


drums were enriched between natural uranium 


and up to 1.25 percent, 75 percent of the 


drums were natural or depleted uranium. 


We also have a lot of new information 


on thorium production. We’ve located 


multiple, multiple documents on thorium 


production information. The petitioners were 


very helpful in providing some documents that 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

27 

NIOSH had not access to previously. We’ve 


conducted several interviews with some former 


Fernald managers and workers. 


We basically put together a matrix, 


which I’ve handed out to you, documenting 


where thorium production occurred by plant and 


by year. We basically have documented that 


production occurred between 1954 and 1979 


except for a couple of years in ’57 and ’58. 


Also, the plants that were involved were 


plants 1 and plants 2, 3, 4, 6, 8, 9 and the 


pilot plant. And this is a slide showing the 


handout that we passed out. 


We located multiple thorium air 


samples spanning more than 20 years. We 


sorted these data by year and fitted them to a 


lognormal distribution. We calculated the 50th
 

and 95th percentile values which we input into 


Atomic Weapons Employer thorium intake model 


which was developed by Battelle. 


For the years where we do not have 


detailed information or we feel that 


information isn’t sufficient, we are going to 


default to the exposure for the maximum year 


that we have documented. And we will assign 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

28 

the maximum year intake for the year where the 


data is not as strong as we would like it be. 


And we believe this is very claimant favorable 


as well. 


MR. BEATTY: Excuse me, Mark. Can I ask a 


question, please? 


MR. ROLFES: Sure. 


MR. BEATTY: On this matrix are you only 


talking about the years of production with 


thorium? Are you not including the over 


packing and remediation effort with thorium? 


MR. ROLFES: Well, as I understand that was 


done in the more recent years. The SEC 


petition is up to 1989, and so I understand 


that a lot of that work began in the late ‘80s 


or early ‘90s. 


MR. BEATTY: I was just noticing it stopping 


at ’77 here, and I knew the petition went to 


’89. 


MR. MORRIS: Well, our rationale for this is 


that’s when production actually stopped, and 


we have, in the technical basis document 


there’s some special storage issues and 


repository issues versus production issues. 


And what we were really missing our data on 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

29 

was production years and so that’s where the 


focus was. 


MR. ROLFES: The Atomic Weapons Employer 


model predicts both inhalation and ingestion 


intake rates. We can actually input the 


actual number of hours into the model. We 


factor intake rates by job title for 


operators, laborers, supervisors, and 


administrative clerical staff. We can 


validate that this is claimant favorable by 


comparing the intakes based on the air 


monitoring data to the coworker analyses, the 


Mobile In-Vivo Radiation Monitoring Lab 


results that we have and analyzed as well. 


The ongoing coworker studies include 


in-vivo data for thorium from the Mobile In-


Vivo Radiation Monitoring Lab which as lung 


count data that was transcribed from 1968 


through 1988. We fitted this information to 


annual lognormal distributions and modeled 


intakes using the Integrated Modules for 


Bioassay Analysis. 


Our uranium bioassay --


DR. MAKHIJANI: Mark, before you leave the 


thorium, how many in-vivo data points do you 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

30 

have in all? 


MR. ROLFES: I believe we had a total of 


3,000 measurements, I believe, is what it was 


for the thorium results. Now that’s either 


thorium or thorium’s daughter products. 


Sometimes it was reported as thorium mass, and 


in the more recent years it was reported as 


Actinium-228 and Lead-212, which are two 


thorium daughter products. 


DR. MAKHIJANI: I couldn’t tell when I 


looked at the thorium mass data what was 


actually being measured. 


MR. ROLFES: I believe it was the same 


daughter products that were being measured in 


the earlier years, but they reported total 


mass based on calibrations that were done 


onsite. 


From the uranium bioassay data that we 


have for Fernald workers almost all of the 


workers were individually monitored for 


uranium exposures. So the need for a coworker 


study is really marginal, but there was 


approximately, I believe, about seven percent 


of the workers that might not have been 


monitored and should have been monitored. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

31 

So what we are doing is taking the 


information from those who were monitored, 


completing a statistical analysis and coming 


up with a claimant-favorable coworker model 


for people that might have been exposed to 


uranium without bioassay data. And we will be 


assigning the recorded results of the 


urinalysis to those unmonitored workers. So 


once again this is another claimant-favorable 


assumption that we are making by assuming that 


a person that wasn’t monitored could have been 


exposed, and we are, in fact, assuming that 


they were exposed. 


MR. GRIFFON: Mark, I’m not sure where it 


makes sense the most to do this in the matrix 


or during your presentation, but I’ve got 


about five or six actions in my head already, 


and it all regards the data. I mean, you’ve 


mentioned that you have put all this thorium 


data together. You have your in-vivo count 


data. I haven’t seen any of it. But I want 


to make sure we track the actions and say 


you’re going to post next month --


MR. ROLFES: Yeah, definitely --


MR. GRIFFON: So maybe as we go through the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

32 

matrix it would make more sense because I know 


these items come up. 


MR. ROLFES: Sure, be happy to. Once again, 


I’ll post all this information. Anything or 


any records that you would like to see, I will 


be happy to put those under the Advisory Board 


Review folder on the O drive. 


MR. GRIFFON: Would that last thing you 


mentioned, the uranium urinalysis records, is 


there an electronic database or are you 


building one or what? 


MR. ROLFES: We have, when we receive a DOE 


response from Fernald, it comes from the HIS20 database. Now we also do receive some 


older, hard-copy records, but I believe many 


of those have been typed into the HIS-20 


database as well. 


MR. GRIFFON: HIS-20. So I think that’s one 


item. I think the HIS-20 if you can post that 


database right off the bat. 


MR. ROLFES: Anything else? 


 MR. CLAWSON: Just that the claimant is able 


to get this information, too. What they can. 


MR. ROLFES: We’re not going to be able to 


provide the, for an individual claim we can 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

33 

provide the claimant’s dosimetry information 


based on a Freedom of Information Act request. 


However, we cannot provide much of the data, 


too, because of Privacy Act concerns, much of 


the data does have people’s names on it. We 


can definitely do what we can to work with the 


claimants and/or petitioners to provide --


 MR. CLAWSON: So what about the petitioner 


that filed this? 


MR. ELLIOTT: This is Larry Elliott. Only 


the Board the contractors can have access to 


the information on the O drive. So if there’s 


anything the petitioner feels they need, we 


would have to work with them through the 


Privacy Act laws. 


MR. GRIFFON: I think Brad’s point, I mean, 


just from our last process with Rocky, I think 


we want to make sure that anything that’s 


publicly shared, we make sure we get it 


readily available to the petitioner, you know, 


at the same time that we all have it if it’s 


publicly available. 


MR. ROLFES: Another analysis that we worked 


on was the radon breath analysis results for 


evaluating radium exposures. And back in the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

34 

early days Fernald, back in the early ‘50s, 


Fernald received approximately 1,300 drums of 


waste that they slurried and pumped into the 


K-65 silos, silos one and two. This material 


contained many of the radionuclides. Radium 


was one of those components in the silos. We 


have 449 valid radon breath samples located 


for the years 1952 through 1954 when the 


workers were transferring the material into 


the silos. We are using ORAU Technical 


Information Bulletin-0025 to interpret the 


radon breath analyses for bioassay data. 


From the calculated radium body 


burdens, we are using the 95th percentile 


value, but we have calculated the 95th
 

percentile value of 0.15 microcuries. From a 


known radium intake, we can then add in dose 


from other isotopes in the K-65 materials 


based on measured and documented activity 


ratios. 


 MR. CLAWSON: You said 1,300, but you’ve got 


13,000. 


MR. ROLFES: Thirteen thousand, thank you. 


 MR. CLAWSON: I just wanted to make sure 


we’re --

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

35 

MR. MORRIS: Mark, yesterday we learned in 


an interview that these radon breath analyses 


samples also represented the workers who were 


in Plant 2, which was just Plant 2 identified 


at the time. It became Plant 2-3 at a later 


date. And so was on the ingestion and 


extraction side. And the raffinate part of 


Plant 3 including -- what was it called? 


MR. RICH: Hot raffinate building. 


MR. MORRIS: Hot raffinate building so there 


was more scope than just this 13,000 drum 


coverage. It was actually the raffinate 


stream at the same time. 


MR. RICH: Some of the separation that they 


did at Rocky Flats, not at Rocky Flats, 


Fernald, and represent the same type of 


raffinate that were delivered from 


Mallinckrodt in the 13,000 drums plus other 


sites. They were all pitchblende which were 


high in radium and thorium. So they did 


sample throughout the plant and the raffinate 


during the raffinate period which is the 


pitchblende separation process. 


MR. ROLFES: We’ve also taken a look at 


thoron exposures. Since we now have 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

36 

additional information on thorium processing 


and storage, we can assign thoron intakes 


based on some documented release factors. We 


also have located historical thoron-specific 


measurements that were made. These are not as 


detailed as we would have liked, but we are 


going to use these measurements to validate 


our analyses. 


We have calculated working level 


months for exposure values for the storage and 


processing areas for all time periods now. 


And we are assigning claimant-favorable 


defaults of up to 20 working level months per 


year. 


The recycled uranium first arrived at 


Fernald in February of 1961, and the primary 


contaminants were Plutonium-239, Neptunium-237 


and Technesium-99. And the limiting 


radionuclide in there was Plutonium-239 which 


was controlled and maintained at less than ten 


parts per billion. 


Historical average results for 


plutonium in the recycled uranium was 


approximately 0.9 parts per billion. There 


was a maximum concentration that ranged up to 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

37 

97 parts per billion which was a shipment that 


came from Paducah Gaseous Diffusion Plant 


tower ash. 


We have assigned a default correction 


to all urine bioassay based on 100 parts per 


billion of plutonium and other contaminants 


beginning with 1961 as well as for all periods 


following. And these defaults we feel are 


very conservative. The tower ash receipt 


operation was identified as a special case. 


MR. RICH: Mark, it would be well to 


mention, I think, the tower ashes were as you 


indicated there was (inaudible) and 


(inaudible) we just found out yesterday. 


MR. ROLFES: Yes, the two workers interviews 


we’ve done yesterday, we had found out that 


this operation where they received the Paducah 


tower ash was a special case where they wore 


respiratory protection, airline respirators, 


and they down-blended the material with 


material from Fernald in order to lower the 


concentrations of the recycled uranium 


contaminants. 


For environmental dose we have also 


re-evaluated historical emission source terms. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

38 

MR. MORRIS: Can I just clarify to that. 


The 97 parts per billion average, was that 


after it was down-blended or -- you’ve got the 


numbers wrong there. Ninety-seven parts per 


billion was the highest observed in any 


subgroup process. 


MR. RICH: Including concentrations so we 


defaulted to the highest plant-wide 


concentration of plutonium and contaminants. 


MR. MORRIS: To proportion to that. What we 


didn’t include was the tower ash because it 


was a special campaign. 


MR. ROLFES: All right, we have used data 


from the RAC Report Number CDC-5 “Uranium 


Emission Estimates”. Thorium emissions were 


estimated using the latest thorium production 


data based on the information that we have 


compiled in this handout. 


DR. MAKHIJANI: Did you have some breakdown 


of episodic versus continuous releases in that 


source term? 


MR. ROLFES: Episodic versus routine 


releases in the source term? I believe we 


did. I’m not familiar with the calculations 


at this time. I’ll get you an answer in just 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

39 

a second here. We’d have to take a look at 


the report and get back to you. 


MR. ELLIOTT: Were you thinking of examples, 


Arjun, of episodic releases that --


DR. MAKHIJANI: Well, in our review and a 


RAC review, there were many episodic releases 


that were documented. But in the ‘50s, which 


was the worst release period, it wasn’t clear 


that the very large releases that happened 


then were documented. 


But there are indications that they 


did have serious episodic releases. I don’t 


know that they were measured. And so it’s a 


kind of methodological problem at Fernald to 


have these extremely large releases some of 


which were very likely episodic and not well 


documented. 


MR. MORRIS: Well, we used data from the RAC 


Report which, as I recall, was one of your 


recommendations at a prior review. 


DR. MAKHIJANI: Right, it was a 


recommendation for the overall source term 


since the RAC Report and other work 


demonstrated that the Fernald official source 


term was wrong and omitted many important 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

40 

elements of the source term. However, I 


haven’t looked at the RAC Report recently, but 


I don’t think they did a very thorough job of 


looking at episodic releases, not because they 


weren’t trying, but I think -- I’ve looked at 


this problem, and I think they looked at this 


problem -- and it is a difficult one. I don’t 


know what we said about it in our review of 


this. 


DR. BEHLING: Well, let me add a couple 


things because I looked at the RAC Report, and 


I believe they were coming up with numbers 


like 5,000, 6,000 curies per releases. But if 


you look at the radionuclide mixture and you 


realize the disequilibrium, you come up with 


values that I calculated to be about 90,000 


curies per year. And so I just looked at the 


nuclide ratios, and on the basis of first 


principles, you have to conclude that the 


release quantities were probably a factor of 


ten to 20 too low. 


MR. MORRIS: So are you saying we should 


have used something besides those reports? 


DR. BEHLING: Well, if you just look at the 


ratio, and it’s in one of my findings where I 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

41 

looked at the radionuclide mixture, and I said 


there’s a disequilibrium here that cannot be 


justified on the basis of five or six thousand 


curies releases. Take a look at that finding, 


and I explained it very definitively. 


MR. ROLFES: We’ll take a look at it. 


DR. BEHLING: And I think among other things 


was the fact that in the ‘80s there was 


basically the silos were sealed off. And so 


what you may have observed later on may not 


reflect the time period when the silos were 


essentially open to the free air. And I don’t 


think that was taken into consideration by the 


RAC Report. Take a look at the finding. 


MR. ROLFES: Anything else? 


DR. ZIEMER: Yeah, is somebody tracking the 


items as we go? Who’s tracking? 


MR. HINNEFELD: I’m doing a relatively poor 


job of it. 


 MR. CLAWSON: Arjun, can I get you to --


DR. MAKHIJANI: I am. You asked me that 


yesterday but --


MR. GRIFFON: But I think as we go through 


the matrix it makes --


DR. BEHLING: Yeah, but I’m hoping that we 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

42 

can actually look at the matrix --


 MR. CLAWSON: I thought we’d start in the 


matrix. But it’s a good point. 


MR. GRIFFON: We can finish the overview, I 


think, right? But then when we go through the 


matrix, I’m going to reiterate some of the 


actions I had with others --


DR. ZIEMER: Well, the overview is becoming 


a little detailed. 


DR. MAKHIJANI: Brad, just so I get my 


charge right, should I start documenting the 


issues? 


 MR. CLAWSON: Well, what I was planning on 


doing was when we got to the matrix, we’d 


bring, we’re probably going to reiterate most 


of this stuff, but we want to make sure that 


we haven’t lost any of this information. 


DR. MAKHIJANI: I’ll make notes and send 


them to you. 


 MR. CLAWSON: Okay. 


MR. ROLFES: Here is the answer to your 


question, Arjun. The new model incorporates 


evaluations for episodic releases that 


occurred. Calculated concentrations near 


buildings include building wake effects. And 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

43 

the annual joint wind rose data was also used 


for frequency, wind speed and wind direction. 


Other radionuclides that in the 


emissions included uranium progeny, Radium226, Thorium-230 are also added to the uranium 


emissions from the uranium ore processing. 


Thorium-232 progeny including Thorium-228 and 


Radium-224 are added to the thorium emissions 


from the storage areas. 


Concentration fields for radon near 


the silos include building wake effects in our 


environmental calculations. And pitchblende 


ore storage from the Q-11 silos were 


identified in the Pinney Report, and these 


have been added to the radon source term as 


well. 


Back to external doses again. 


MR. MORRIS: This is environmental external. 


MR. ROLFES: Okay, environmental external 


doses. The direct radiation from Radium-226 


and the progeny in the K-65 silos were derived 


from environmental monitoring data after 1976. 


The annual doses prior to 1976 near the K-65 


silos are extrapolated from dose measurements 


in the early 1950s and ‘60s. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

44 

And that is the update on the 


technical issues that we are incorporating 


into our revision of the Fernald site profile. 


DR. ZIEMER: Mark, could you or one of the 


O-R-A-U team talk a little bit about the 


breath analysis capabilities in those days? 


What was the methodology and calibrations and 


also talk about same on the thoron and how 


were they distinguished? 


MR. MORRIS: The radon breath analysis was 


done at University of Rochester under 


subcontract. Exhaled air volume was captured 


in a cylinder of some description. I think it 


was a round --


DR. ZIEMER: Charcoal or was it --

MR. MORRIS: No, it was actually --

DR. ZIEMER: Oh, they evacuated. 

MR. MORRIS: -- evacuated some, I think it 

was they were given an evacuated sphere if I 


recall. And then it was shipped to the 


University of Rochester where it was analyzed. 


It turns out we have an OTIB on this method in 


the repertoire of the Oak Ridge Team. The 


analysis then was calibrated back to, was 


traced back through calibration to radium 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

45 

full-body burden. And from that the dose 


calculations are bounding from there. Yeah, 


there’s certainly a question about --


DR. ZIEMER: And the thoron was done in a 


similar manner? 


MR. RICH: No, the thoron breath analysis 


significance. These are purely theoretical. 


MR. SCHOFIELD: Oh, okay, it was talking 


about thoron breath analysis as well. 


MR. ROLFES: I apologize. Those were not 


thoron breath analyses that were conducted. 


Those were actual thoron measurements that 


were completed within the areas that were 


processing thorium. The thoron measurements 


that were conducted were air samples that were 


collected, counted, I believe immediately and 


then counted again after several minutes I 


think it was. 


I’d have to take a look back at the 


analyses to determine the amount of time. But 


it is documented in the air samples that we do 


have to determine both the short-lived as well 


as the long-lived activity. 


MR. SCHOFIELD: How frequent were these 


samples taken? 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

46 

MR. ROLFES: I wouldn’t be able to make a 


judgment without looking back at the records 


right now. These were very limited. There’s 


probably a few tens of results as I recall. 


MR. MORRIS: Well, you’re talking about the 

thoron? 

MR. ROLFES: The thoron, yes. 

MR. SCHOFIELD: So they have the potential 


for missing a lot of dosage there. 


MR. ROLFES: Well, that’s true that thoron 


measurements were not conducted routinely, but 


what we have done is taken a thorium 


production, we taken the thorium production 


information. And we have calculated release 


fractions and used those thoron measurements 


to confirm our analysis. So we have come up 


with an analysis that’s very claimant 


favorable. 


DR. MAURO (by Telephone): Mark, this is 


John Mauro. Can you hear me? 


MR. ROLFES: Yes. 


DR. MAURO (by Telephone): I just have a, 


from a perspective, you’re referring to a 


great deal of information. Just I wanted to 


confirm that the material that you’re 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

47 

describing, is that material contained in a 


recent version of the site profile and/or in 


the evaluation report? Or is this material, 


the analysis that you’re describing, this is 


material that has been developed relatively 


recently and is being incorporated into a new 


revision, an upcoming revision, of the site 


profile? 


MR. ROLFES: This is information that was 


assembled and evaluated based on the SEC 


report and based on the SEC investigations 


that NIOSH conducted. This information is, in 


fact, being incorporated into a revision of 


the site profile for Fernald. 


DR. MAURO (by Telephone): Okay, but it’s 


not in the version that’s currently available 


to us. 


MR. ROLFES: Correct, it is not in an 


approved public version at this time. 


DR. MAURO (by Telephone): I just wanted to 


be a little oriented because it’s a lot of 


material that I wasn’t aware of from my 


reading of the previous documents. 


MR. ROLFES: Yeah, as I mentioned, this was 


one of the first few technical basis documents 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

48 

that was completed. NIOSH was trying to get 


some answers for claimants in a short amount 


of time. And we realized that the information 


that we had at that time was not complete and 


realized that we would, in fact, have to 


revisit this information. This is one of the 


many important source terms that we are adding 


into the technical basis document. 


DR. MAURO (by Telephone): I appreciate 


that. And also as I understand it you’re also 


then, the evaluation report that we recently 


reviewed and put a report out, that material 


is not contained or is it referred to in the 


evaluation report? 


MR. ROLFES: What material is that, John? 


DR. MAURO (by Telephone): The evaluation 


report for the SEC petition that was put out 


and that SC&A recently reviewed and submitted 


a report. I just wanted to get a little 


clarification of how much of the material that 


we’re talking about right now, or the findings 


perhaps, has been incorporated into your 


evaluation report. 


MR. ROLFES: I’m not sure I understand --


 DR. WADE: The materials that you’re --

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

49 

MR. ELLIOTT: He wants to know if our 


evaluation report addressed any of this new 


information, and the answer is no. 


DR. MAURO (by Telephone): Okay, that’s all 


I’m asking. 


 MR. CLAWSON: So when this information goes 


in the TBD, I realize that they’re a living 


document and so forth like that. There’s 


going to be page changes and so forth. 


MR. ROLFES: Most definitely. This will be 


incorporated into the technical basis document 


for use in dose reconstructions, and that 


approved version will be made available to the 


public. This information has been informally 


documented in draft papers, and we’re in the 


process of getting revisions to the 


environmental section of the TBD in the 


internal primarily. 


 MR. CLAWSON: We’re going to get to the 


matrix in a minute, but you’ve handed out this 


thorium operation, and you’ve got Xs. What 


are they actually representing? Because I’m 


seeing a lot that have four, some have three. 


MR. MORRIS: That looks like an old copy to 


me. I’d refer you to the one that’s in the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

50 

handout itself. And let me describe what 


would be around that. 


DR. ZIEMER: Which handout are we --


MR. ROLFES: I apologize. I didn’t provide 


a copy of these slides. 


 DR. WADE: Do you want me to make copies of 


that before you -- I can make copies of that 


before you describe it to people. 


MR. MORRIS: If you could visualize mass 


numbers in this line of Xs like 300 metric 


tons or 200 metric tons. It represents if we 


had individual year data for production, we 


put that in there. If not, we put the total 


that was listed for that thorium campaign over 


those years. 


DR. MAKHIJANI: I’m lost. I cannot, I guess 


I need to near a piece of paper. 


 DR. WADE: Can you put that slide up? 


 MR. CLAWSON: Do you have that matrix in 


your slide show? 


MR. GRIFFON: I think we need a copy of the 


whole --


MR. ROLFES: Yeah, I didn’t provide a copy 


of the presentation. I apologize for that. 


MR. MORRIS: You can see that there are 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

51 

numbers interspaced into there, and sometimes 


we have real production data available for an 


annual basis and sometimes we didn’t. And 


when we didn’t have production data annualized 


basis, we just said that that was to total 


mass through that campaign over the years. 


DR. MAKHIJANI: And is the production geared 


to the dose reconstruction in some way? 


MR. MORRIS: No, that will not gear to the, 


the air samples will drive the dose. It won’t 


be the production data. 


 DR. WADE: Now what is your pleasure with 


regard to hard copy of the slides? Would you 


like those made and distributed as quickly as 


possible? 


 (affirmative responses) 


 DR. WADE: I need a copyable version. 


 MR. CLAWSON: I appreciate that. I was just 


trying to figure out what all that, what was 


the meaning. What was represented. 


MATRIX DISCUSSION
 

So, Hans, I guess what we’d like to 


start is just start out with the first item on 


the matrix and start off our discussion. 


DR. BEHLING: Let me make a couple 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

52 

statements beforehand. First of all, my 


report was obviously geared towards the SEC 


evaluation report as well as the technical 


basis documents that define Fernald. And so 


we’re dealing with issues that in part have 


been modified as a result of the more recent 


information that has been presented to you. 


But I also want to make a couple 


comments here. In my report I identified 29 


findings, and I know there’s a certain 


subjective element to the finding what a 


finding is. In my way of thinking, in certain 


instances under different circumstances, some 


of the findings that I identified would not 


have been considered a finding. 


When I looked at the totality of the 


picture, and I can give you sort of an analogy 


as a finding as being a spoke on a bicycle 


wheel. If you pull out one spoke, the bicycle 


rides just as nicely as it did with that spoke 


still in place. But if you take enough spokes 


out, the wheel fails to function. And I 


looked at the findings in a collective term in 


saying how many findings can you possibly have 


before the system starts to really be 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

53 

questionable. 


One of these, or even several of them, 


would have probably been regarded as an 


observation that says, yeah, you can fill in 


the gaps. You can easily accommodate that 


deficiency. But when there are so many 


findings, and so many things that are 


potentially amiss, then I start to look back 


and say, no, this has to be a finding because 


it’s part of the larger problem. A single 


crack in the wall makes no difference to the 


integrity, but if you have a crisscross or a 


spider web of cracks, the wall crumbles, and 


that’s how I viewed this. 


And the other thing I wanted to point 


out is an issue that has been raised numerous 


times in the past with regard to Fernald, and 


I believe some of the petitioners raised that 


question. And that is we hear an awful lot 


about what we can do, but the real question 


is, is it plausible? 


There’s a lot of things that in theory 


can be done. And you heard again today a 


tremendous amount of new information, and we 


have radon breath data and so forth. But the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

54 

question is can we necessarily mate certain 


data with people, and what happens when you 


don’t have data. We have default values. 


For instance in the case of radon 


breath samples I hear that, oh, yes, we do 


have radon breath samples for some, but 


obviously, not everyone. Are we going to use 


20 working level months per year as a default 


value? And will that be used for a person who 


may be a potential claimant that has to be 


compensated? Or is this a default value, once 


again, that is only used to maximize the dose 


and to say, no, sorry, even 20 working level 


months per year assignment won’t get you over 


the 50 percent. 


There are a lot of unanswered 


questions I have with regard to the complexity 


of this issue, and the ability to apply these 


complexities out in the field. I know there’s 


a lot of experts here. Mark and Stu and Jim 


Neton and others, they’re always a party to 


these discussions, and they always know the 


answer that could be used to satisfy a certain 


deficiency. But the question is they’re not 


the people who will be doing the dose 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

55 

reconstruction. 


And the people out there who are not 


party to this, may not have any clue that when 


there is no radon breath data, that their 


potential exposures should go to a default 


value of 20 working level months per year. 


That I don’t know, and I always question the 


ability of the dose reconstructors to actually 


make use of the information that we’re hearing 


about today and in the past. 


MR. ROLFES: Well, Hans, I can say that I’ve 


probably done more Fernald dose 


reconstructions than anyone within NIOSH and 


OCAS outside of the contractors. I know Mutty 


Sharfi. I’d like to have him go ahead and 


make a comment about that. 


 MR. SHARFI: Actually, one of the reasons 


why me and Karin are here is we represent the 


dose reconstruction group, so we can play a 


role in any additional information that 


provided more fundamental changes in the 


approaches in how we assign doses, that there 


is a dose reconstruction understanding of all 


the new aspects or any changes to the site 


profile. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

56 

So it’s not just a blanket change to 


the site profile where it’s not clearly 


defined into the dose reconstruction side. So 


we do try to take an active role. And the 


same thing in Rocky Flats where we would take 


an active role in to making sure that the dose 


reconstruction side is in agreement and 


consistent with what the findings are from 


this group. 


DR. BEHLING: Now let me ask the question 


here because one of the previous meetings you 


showed a slide that says to date we have 


somehow close to 700 claims that haven’t been 


completed of which -- no, 90 percent of the 


claims that had been submitted were completed. 


And that was months ago back in early of this 


year, February. To date I assume we’re 


probably closer to 95 percent of the claims 


that have been submitted have been completed. 


And, of course, I’ve looked at some of 


the claims. I haven’t done an exhaustive 


search, but I realize that many of these 


claims have been completed on a basis of TIB0002. And a lot of the information that is 


obviously at this point only in the process of 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

57 

being formulated, let alone get implemented. 


And so we’re 95 percent probably home free in 


claims, and we’re still in the process of 


modifying the TBD. We’re still in the process 


of establishing a Patel* dose model that 


involves a generic AWE procedure. 


And I’m just questioning. We’re going 


to be still talking about modifying when there 


are all the claims have been done. And they 


were done by old methods, and methods that at 


this point have been abandoned including the, 


for instance, the K-65 silo --


 DR. WADE: Okay, let’s let NIOSH answer 


that. 


MR. ELLIOTT: I’d like to speak to another 


level of this though, Hans. There’s another 


level that we didn’t talk about here just a 


moment ago, and that is the reviews that goes 


on with regard to dose reconstructions 


completed under a specific approach, and any 


changes that occur regarding that approach. 


So you have that as another level, I hope, of 


assurance that these things are getting 


attended to properly in the claims. 


The other thing I want to speak to is 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

58 

that, yes, we made calculated decisions on 


when to put a technical approach into dose 


reconstruction play knowing full well that 


there were aspects that hadn’t been fully 


developed in that approach or a full, best-


estimate dose reconstruction. 


Our regulations enable us to employ 


efficiency measures in our dose reconstruction 


approaches, and this is one of those ways we 


employ an efficiency measure. To use a tool 


as soon as we possibly can to give people 


answers in a timely fashion. 


A rule also enables us to go back and 


look at denied claims and re-examine them with 


new understanding, new tools, new approaches 


and better designs in order to make sure that 


the compensation decision is correct. We see 


this as working to the benefit of the claimant 


population. 


DR. BEHLING: Well, as I said, I clearly 


understand the efficiency. Most of you know 


that I’ve been very much involved in this 


project from day one, and I clearly appreciate 


the need for a new efficiency measure. But 


when I see a TIB-0002 protocol where a person 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

59 

gets assigned 28 radionuclides on day one of 


his employment, and he’s there for 30 years, 


to what extend have we verified that the 


actual doses that the individual may have 


received far exceed what might otherwise --


And I realize TIB-0002 is intended for 


people who were never even monitored. People 


who have no reason to be exposed. It is 


strictly an efficiency tool. And I fully 


grant you the fact that when, under those 


conditions, that model is used it is likely 


always, probably 99 percent plus, likely to 


overestimate the real dose. 


But in this case, when I see a TIB0002 being applied with a 28 radionuclides on 


day one of this occupational involvement 


employment at Fernald, and assume that he’s 


necessarily going to supercede or transcend 


his actual, I have to really question it. 


MR. HINNEFELD: Well, Hans, in cases -- I’m 


sorry, Stu Hinnifeld from NIOSH. In cases 


where TIB-0002 is used and a person, for 


instance, had monitoring data. It’s only used 


in a case where it can be demonstrated from 


his monitoring data that his exposure based on 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

60 

monitoring data is lower than the TIB-0002 


dose. That’d be the only cases when a TIB0002 approach should be used on personal 


monitoring data. 


So, I mean, it has to be demonstrated 


in order to use that approach on that claim. 


So a TIB-0002 approach, something over a 


hundred years of exposure at the MDC, 


something over a hundred MDC years. So, I 


mean, it is a huge, huge intake given all at 


once. But it’s equivalent to hundreds of 


years at the maximum dose concentration, so a 


huge amount. And it would be very hard to 


conceive of an actual exposure situation where 


someone would exceed a TIB-0002 intake. 


DR. MAKHIJANI: We actually, this is a 


finding in our site profile review. It’s 


finding 5.2.1. It refers to earlier work that 


we did on Mallinckrodt. Earlier work that we 


did on Mallinckrodt in which we had pointed 


out that in some cases the TIB-0002 doses at 


Mallinckrodt where people were exposed to a 


certain raffinate stream for not all organs 


generally, but for instance, for the bone 


surface, may be exceeded and that the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

61 

recommendation was that NIOSH actually 


verified this in the case of Mallinckrodt and 


the recommendation in our site profile review. 


And that finding is that NIOSH verify this in 


regard to certain raffinate streams for 


Fernald. Because I am not confident that TIB0002 will result in a conservative dose. And 


in doing the site profile review, I did look 


at some dose reconstructions, and I am not 


confident that what you are claiming to be a 


maximum dose would survive a close scrutiny 


for raffinate stream. In fact, there aren’t 


good data for certain raffinate streams so I 


don’t know how you could even go about 


verifying it. We’ll cover it during the 


matrix. I think maybe we should get to the --


 DR. WADE: Right, what we should do is get 


to the --


MR. HINNEFELD: This is pretty far afield 


but it’s --


MR. ROLFES: To comment on what Arjun said, 


we wouldn’t be using TIB-0002 to calculate a 


bone surface dose. That is not one of the 


organs that we would use TIB-0002 for. In the 


case of a bone cancer, as you’re referring to, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

62 

for the target organ would be the bone 


surfaces, because of the number of people that 


have bioassay data from Fernald, we would use 


the uranium bioassay as well as exposure from 


thorium based on the air monitoring data that 


we have. And those two components are usually 


sufficient to make a compensation decision. 


 DR. WADE: I think it’s also important that 


we stick with the matrix. I think general 


discussion is good, but I think the grist of 


this really comes with the discussion of the 


issues in the matrix. 


 MR. CLAWSON: Right, there’s only one point 


that I want to make before we start in the 


matrix. You know, we all work to procedures 


and so forth, and this is why it’s so critical 


that Board, one of the things we’re tasked 


with is data integrity and also if the process 


works. So this is why getting this 


information on the O drive or so forth is so 


critical to us. And that’s why I know that I 


sometimes beat on it so much. It’s so that we 


can actually verify what’s out there and so 


forth. 


 DR. WADE: Can I make one other observation? 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

63 

I think it needs to be said for the record 


though I think everybody around the table 


probably understands it. I mean, NIOSH might 


well have undertaken dose reconstructions 


early in the process and now the science has 


evolved to a new point. NIOSH is bound to go 


back and re-do those dose reconstructions, and 


I think everyone understands that, but I think 


it’s important to say that. 


MR. GRIFFON: And one more thing before we 


get into the matrix. This is really for 


Mutty. I have “Basic Guideline for Fernald 


Dose Reconstructions”. 


MR. ELLIOTT: It’s probably old. 


MR. GRIFFON: Yeah, it’s probably old 


 MR. SHARFI: It’s not going to include any 


of the --


MR. GRIFFON: That’s what I was going to 


say. I have a 6-13-0-6. If you could provide 


the latest draft to him, that would be useful. 


It wouldn’t even include this new stuff. 


 MR. SHARFI: Correct, it still would not 


include the newer stuff. 


MR. ELLIOTT: I’m sorry. I missed that. 


You’re asking for what? 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

64 

MR. GRIFFON: The DR Guidelines that are 


currently being used, but they wouldn’t even 


include these updates, no. 


MR. HINNEFELD: It wouldn’t address this new 


information. 


MR. ELLIOTT: We won’t. We want it as a 


matter of logistics. We won’t update those 


until these discussions are done and whatever 


decisions are arrived at. 


MR. HINNEFELD: It probably will be 


consistent because the site profile hasn’t 


changed since almost it came out in 2003, so 


probably little information as we work with 


Task 3 to get clarification and make sure we 


fully understood areas. 


MR. GRIFFON: Probably one of the first 


things you read in this one is that if there’s 


no external or bioassay results, use 


environmental dose. And what Mark presented 


was we got 70 percent of the people without 


bioassay results, but we’re going to develop a 


coworker model and use that. So already --


MR. SCHOFIELD: And that would be something 


we’d go back and have to reassess those claims 


if that’s the way we did them. 

1 

2 

3 

4 

5 

6 -- 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

65 

MR. GRIFFON: Right. But we did that in 


Rocky. 


MR. SCHOFIELD: Yeah, there’d be no --


MR. GRIFFON: -- retract those and make sure 


for like Super-S and for the other things that 


MR. ELLIOTT: It was part of the program 


evaluation, yes. 


FLUOROPHOTOMETRIC URINALYSIS DATA


 MR. CLAWSON: Okay, if we’ll start into the 


matrix, limitations associated with the use of 


fluorophotometric urinalysis data. 


DR. BEHLING: Arjun, let me, I’d like to 


introduce the issue, and then maybe you can 


respond. The issue is really one, and I’ve 


heard it before that our principle approach 


for dose reconstruction will rely on urine 


data. And, of course, a urinalysis was 


limited fluorophotometric method which only 


establishes the amount of uranium. It does 


not distinguish between different isotopes of 


uranium nor does it define the activity. 


So when you have, obviously, a mixture 


of uranium plus, of course, all the 


contaminants that might have come from the raw 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

66 

source term that involved Congo ore as well as 


the recycled uranium. We don’t have any of 


that data. We don’t have solubility, and yet 


somehow or other we’re going to, I’m led to 


believe we’re going to use a very claimant-


favorable assumption in just finding a 


quantity of uranium in urine. 


So if you have, let’s say, 50 or 100 


micrograms of uranium in a liter of urine, 


you’re going to somehow or other convert that 


into an activity that also not only defines 


the total activity of uranium and assume that 


that total activity is U-234, but you’ll also 


make assumptions regarding the solubility, et 


cetera, et cetera. And I guess I have to 


question what is it that you’re going to use 


here. 


Obviously, with urine you always have 


to be aware of the fact that the most 


claimant-favorable assumption is that it’s 


always insoluble even if it’s a non-metabolic 


tissue that in question. And is this an 


assumption that will be made so that every 


time you have a urine sample, that the 


assumption is that it is an inside form of 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

67 

urine and that you have to somehow or other 


make a default value as to what the 


radionuclide mix is. 


I’ve heard two percent enrichment 


because that’s a critical issue here to 


convert mass into activity. And yet I know we 


have information out there that large 


quantities of seven percent uranium enrichment 


was done. So to what extent are we going to 


accommodate all these variables into a single 


format that says we don’t know anything other 


than quantity in a 24-hour urine sample, but 


somehow or other we want to be claimant 


favorable in assuming that it is the right 


solubility and there is no variable. 


It’s only insoluble that is always 


regardless of what the tissue is most claimant 


favorable. And, of course, also the issue of 


converting --


MR. HINNEFELD: That’s not, that’s not --


DR. BEHLING: Well, we’ve done that before. 


You always assume that if it’s an air sample ­

-


MR. HINNEFELD: The intake was bigger. 


DR. BEHLING: -- if it’s an air sample, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

68 

clearly, it would be much more favorable to 


assume that any other tissue than the lungs 


would be a proper. But we’re dealing with 


urine now. Let’s remember that. And if 


something is very insoluble and still shows 


up, that just means you’ve taken in a lot more 


than if it were soluble. I’ve done these 


calculations --


MR. HINNEFELD: Oh, sure, the intake’s much 


bigger. 


DR. BEHLING: And the dose to an organ based 


on a given value is always higher for 


insoluble. 


MR. GRIFFON: The intake’s higher. 


DR. BEHLING: That’s what you’re trying to 


find out from a urine sample. You’re going to 


have to convert --


MR. GRIFFON: But the next step is not 


necessarily intuitively obvious to me. The 


dose may not be higher to the organ because 


you’ve got to assume the same solubility when 


you carry it through for your dose 


calculations. 


MR. HINNEFELD: Once it’s in the 


bloodstream. Once it’s in the bloodstream --

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

69 

MR. GRIFFON: We have on many work groups. 


MR. HINNEFELD: Yeah, we’ve been through 


this many times. 


DR. BEHLING: In the calculations I’ve done 


it always shows that insoluble is the most 


claimant favorable. 


MR. ROLFES: But not necessarily the dose. 


 MR. SHARFI: When we do a dose 


reconstruction, we always look at all 


solubilities and assign which ever will give 


the biggest dose to any, whichever organ is of 


interest anyway. I mean, we don’t default to 


any particular solubility. If a soluble form 


would give a larger dose, then we’d use that. 


If an insoluble would give a larger dose, then 


we would use that. It’s not bounded by a set 


solubility. We will find the most claimant-


favorable solubility, and that’s what is 


assigned. 


DR. BEHLING: Okay, that’s, the starting 


point is urine. 


MR. ROLFES: So anyway, the NIOSH response 


to the issue of the fluorophotometric or 


fluorophotometric urinalysis data, we believe 


that this is not an SEC issue. What we are 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

70 

doing with the bioassay data that we have, the 


urinalysis data, we are converting the uranium 


mass to an activity excreted on a 24 hour 


basis. 


And in order to complete this 


calculation, we take the mass value observed 


in urine, correct it to an amount of urine 


excreted for 24 hours, multiply that value of 


mass times the specific activity of the 


uranium enrichment. And then we assign 


intakes of that material based on claimant-


favorable solubility information. And we 


calculate the internal dose from that intake 


assuming that all uranium that was inhaled was 


from, the internal dose that is calculated is 


all U-234 because that has the highest dose 


conversion factor. 


So there are very, there are several 


claimant-favorable assumptions within there 


that really don’t make the issue on enriched 


uranium or low enriched uranium as big of an 


issue as it might appear to be. Because we 


are not assigning, we’re not doing best 


estimate claims for the greatest amount of the 


population at Fernald. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

71 

Our estimates are typically very 


claimant favorable. We are assigning chronic 


intakes over the entire employment history 


based on a person’s urinalysis data rather 


than reconstructing specific, episodic 


intakes. Generally, when we are calculating 


intakes for a person, it is much more claimant 


favorable to assume the chronic exposure than 


an acute intake. 


MR. HINNEFELD: Well, the key element here, 


Mark, is the enrichment. 


DR. BEHLING: The principle element is the 


enrichment and what is the default value. 


MR. HINNEFELD: Because that drives the 


specific activity, and that drives the whole 


thing. 


MR. ROLFES: Exactly. I’ll have to ask 


Bryce for the, for support on this, but I 


believe after 1961 we are assuming a one 


percent enrichment at this time, and after --


is it two? Two percent. I apologize, two 


percent enrichment. 


DR. MAKHIJANI: Nineteen sixty-four or ’61? 


The TBD says ’64. 


MR. ROLFES: Okay, I apologize and --

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

72

 MR. SHARFI: ‘Sixty-one when the type of 


uranium starts, and then ’64 is when enriched 


uranium, enriched recycled uranium starts. 


DR. MAKHIJANI: The reason I ask as in our 


review we actually said that that was not 


correct. That enriched uranium began, if you 


look at the materials accounting data at 


Fernald, you will see that enriched uranium 


began to appear at Fernald in 1950s. And the 


entire set of production data in the TBD is 


full of internal contradictions. 


And I don’t know if you’ve sorted this 


out in the new work that you’ve done, but it 


doesn’t correspond to the materials accounting 


data either in any of the streams for recycled 


uranium for the various enrichments. So I 


don’t believe that until these contradictions 


are sorted out you can actually assign, what 


one can agree as we did in the reviews that if 


you assign two percent for everybody from ’64 


on, that it would likely be claimant favorable 


for most workers. But in the context of an 


SEC where you have to have a more rigorous 


standard, you actually haven’t addressed the 


five percent, the ten percent or more than two 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

73 

percent even though it wasn’t a vast 


proportion of the material. 


And secondly, the materials 


accounting, the materials flow from Fernald 


was very different than what you’re assuming, 


and enriched uranium was present at Fernald in 


the ‘50s. And so I don’t know where you got 


your information, but certainly the materials 


accounting data at Fernald are not, do not 


support what is being done in the TBD. 


MR. ROLFES: The great amount of material at 


Fernald in the early time period was naturally 


uranium, and --


DR. MAKHIJANI: This is correct. 


MR. ROLFES: -- and there may be, there may 


have been a very small amount of enriched 


uranium --


DR. MAKHIJANI: This is not correct. You 


have not looked at the materials data 


carefully. I pointed out that actually there 


are internal contradictions. Your recycled 


uranium amount is bigger than your total 


uranium process amount. You’re off in your 


total production by a factor of two when 


you’re saying 200 or more. You’re saying 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

74 

200,000 where the total at Fernald was about 


600,000 metric tons according to the materials 


account data. 


So I think you have a number of 


problems that we pointed out in the site 


profile review that apparently haven’t yet 


been addressed. And the very material to the 


SEC discussion because unless you’re willing 


to assign an arbitrarily high enrichment up to 


the maximum that was every assigned, you have 


to have the materials flow for various 


enrichments and who was working with what. 


And I haven’t seen any information that 


allowed you to do that. 


MR. ROLFES: Well, NIOSH would like to 


request the same data that you have available 


to you. 


DR. MAKHIJANI: Well, we’ve given citations 


to the plant documentation, and I’d be happy 


to, they are in the review. They’re memos, 


and they’re filed every year with the 


Department of Energy. 


MR. ROLFES: Well, if you could be helpful 


to us and provide that, we would appreciate 


it. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

75 

However, the enrichment issue we do 


not feel is an SEC issue because it is a 


selection of, we can basically assume exposure 


to any level enrichment that occurred at the 


site. Like I said, this issue is not a 


significant issue for the great majority of 


the claims. And actually, when we process a 


claim, when we complete a dose reconstruction, 


this issue, based on our approach, we are 


assigning very claimant-favorable doses. 


Now this is an internal dose issue, 


and I’d be happy to run through an example or 


provide an example to the Advisory Board and 


SC&A on how we would reconstruct internal dose 


for Fernald to basically show that this issue 


is not going to be a significant issue for the 


great, great majority of the claimants that we 


are completing dose reconstructions for. 


DR. MAKHIJANI: Could I ask the two Board 


members for some guidance in regard to how we 


are thinking about SEC issues under 22-CFR-83? 


Whether we are supposed to discuss all the 


members of a class and all the covered cancers 


or whether we’re discussing claimant favorable 


for the majority of the workers. Because a 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

76 

lot of the comments are going to be the same, 


and unless we have some common understanding 


of what we’re discussing, we’re going to be 


repeating the same comments. 


Whether something is claimant 


favorable for a vast majority of workers, 


which I would agree to and already written in 


the site profile review, but whether you have 


information to cover the class of workers is a 


very, very different and more rigorous 


question. And so I’d like to know what we’re 


commenting on, whether we’re actually in an 


SEC discussion or dose reconstructions. 


MR. GRIFFON: Well, we’re in an SEC 


discussion, and it is all members of the 


class, all the stuff. So that’s my take on 


this. And so I would say, I mean, I think we 


have to have some fall backs and one might be 


an example related to this. 


Another action I wrote down was that 


we need to have more information on NIOSH’s 


assumptions regarding which levels. And then 


SC&A’s action is to provide those references 


that they have so that we can get that clear. 


I think, Mark, you’re probably saying that 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

77 

even if we find out that the level was higher 


for a certain time period, unless there’s an 


adjustment, that’s not really, and we can 


bound it. 


On the other hand we do have this, 


well, in our procedures we say proof of 


principle. So we want to sort of nail it down 


like when are you going to apply, if we decide 


it was a higher percentage for a certain time 


period or for a subset of workers. 


We want to understand that a little 


better. So I think we need to understand 


those assumptions and then maybe get a sample 


on the table as well of how you’re going --


MR. ROLFES: Based on some interviews that 


we’ve done with some former workers, we know 


that the area where the higher enriched 


materials were, in fact, blended, and so we 


would look into that. From the records that 


I’ve reviewed, I have seen indications in 


documentation of higher assay material being 


worked with and air sampling, breathing zone 


air samples taken during that time period as 


well. So we could look at that as well. 


MR. GRIFFON: So I’ll try to track these 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

78 

actions as we’re going through because I 


think, and then maybe at the end of the day we 


can summarize these because I think we tend 


to, we want to make sure we stay on them, 


right? We don’t want to let NDRP slip, right? 


 MR. CLAWSON: So you’ll help me track some 

of these? 

MR. GRIFFON: Yeah, I will, yeah. 

DR. ZIEMER: Arjun, did your original report 


include those references? I’m just looking at 


the report now, and they’re in the reference 


list? 


DR. MAKHIJANI: There’s at least one 


reference to an incident in 1986. I’ll check. 


 MR. CLAWSON: Mark, I’ve also got one 


question. How much uranium did Fernald 


actually produce? 


DR. MAKHIJANI: Nineteen eighty-five, I’m 


sorry. 


MR. ROLFES: Off the top of my head, I don’t 


want to throw a number out there. Bryce or 


Mel? 


MR. CHEW: Ask the question again. 


 MR. CLAWSON: How much uranium did actually 


Fernald produce in their life? 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

79 

MR. CHEW: I don’t have that. 


 MR. CLAWSON: Let me tell you why. Because 


I go into the TBD, and I see one reference. 


And it go to the DOE site, and I see three 


times that amount. And in several different 


other positions one of my questions and why 


I’m bringing this up is I see that I can’t get 


a clear, I believe your TBD -- I can’t 


remember how many thousands of tons it was. 


It was 30,000 or something like that, and I 


see on a DOE site that it was actually 120,000 


that was produced. So there’s a difference of 


almost three percent right there. 


And actually, I went to one of their 


little videos of the clean up of it, and they 


said that they had basically about the same 


amount as what you guys were saying it 


produced over the life sitting there that they 


had to dispose of. So one of the things that 


I see in this, and I know the TBD is a living 


document. We understand that. But there is a 


clear disconnect in what was actually 


produced. 


MR. ROLFES: Keep in mind that Fernald 


didn’t just produce uranium metal. They also 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

80 

received shipments of uranium metal from other 


sites, so those could be some of the issues 


why the numbers don’t match up. It may be an 


issue of the actual amount produced for 


shipment, you know, to Savannah River site and 


Hanford and other locations or produced 


specifically for the AEC. Because there was 


some work in the later years that was 


conducted for the Department of Defense as 


well. So I’d have to take a look at the 


numbers in order to make a judgment. 


 MR. CLAWSON: Well, and I’d like that to be 


an action item because one of the things, it’s 


like with me. I realize, and I’m a person 


that’s always said this about every one of the 


sites. We’re all intertwined. We get an 


awful lot of stuff from Savannah River. I 


think in my data right now I’ve got Savannah 


River, Rocky Flats, Hanford, all this 


different stuff. 


But one of the things about uranium 


metal that I’ve found, or uranium product that 


I’ve found that’s different is being a nuclear 


material custodian when I have fuel come in 


from another facility, it doesn’t go on my 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

81 

books. The only thing it goes into me for is 


criticality concerns and to assure that I’m 


not in a critical state and so forth. And I 


produced an awful lot of it through, but I 


never take responsibility. That is always on 


the other companies’ books. 


MR. RICH: May I say something? 


MR. ROLFES: Sure. 


MR. RICH: Let me make just a couple 


comments about inventories and material flow 


through Fernald. In the technical basis 


document, for example, there was an extensive 


study done by, for recycled uranium material 


flows. It was recognized that there were some 


conflicts between the various sites. When we 


did the recycled uranium study, for example, 


didn’t all add up until three years later --


it took them three years -- to do another 


study, a follow-on study in 2003. 


The only problem with that was an 


incomplete study that only dealt with the 


primary shipments from the primary recycled 


uranium shipment which was Savannah River and 


Idaho. And so that did not include the 


secondary shipments. So clearly, even within 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

82 

the recycled uranium material mass flow area, 


that ore, some disconnects as you pointed out, 


Brad. When you’d get it in for a certain 


purpose, you keep it on a separate inventory 


tracking system. 


Now as far as the total mass flow at 


Fernald, see, they did the pitchblende, which 


is a natural. They also took material, they 


had a contract to take all of the yellowcake 


from all of the United States processing 


centers. And for a period of about five 


years, they processed that, which was a 


natural uranium, high volume, high mass flow. 


Now the point being that there are differences 


in mass flow for different programs. 


And the technical basis document does 


not address all the mass flows. The mass 


flows that are in the technical basis document 


are primarily recycled uranium in an attempt 


to do not only the primary, because that 


secondary flowed into Fernald, and it’ll be 


different than what you can find in other 


publications. 


Now if we go to get total mass flows 


of all uranium from all sources, that’s a 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

83 

different challenge. And probably doesn’t 


relate directly to does reconstruction. And 


so if that statement has any clarification, it 


is related to what you’re seeing on the 


reports now, I think there’s a justification 


for it. 


 MR. CLAWSON: So you’re telling me that none 


of your dose reconstruction is based on the 


amount of uranium ore product that they have? 


MR. SCHOFIELD: Bioassay data. 


MR. RICH: It’s strictly on bioassay data, 


but what we tried to keep track of total types 


of material in the system and looked at, for 


example, the average enrichment in the back 


house filler, for example, over an extended 


period of time to get a feeling -- and by the 


way, that averaged out 0.7 enrichment. It 


averages out natural uranium because that’s 


primarily the bulk of the material that was 


processed. And then what we’ve said is that 


to default to a two percent enrichment is at 


the level that would cover all but a few, a 


minor exceptions. 


 MR. CLAWSON: I think it’s something that, I 


guess personally for me looking at the TBD and 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

84 

probably, I guess I’ve got to look at it like 


the common person looking at that, there is a 


disconnect there and might be something we may 


want --


MR. GRIFFON: Clarified. 


 MR. CLAWSON: -- clarified. 


MR. RICH: There possibly could be a 


clarification even in defining the fact that 


if you compare this with other material flow 


sources that there will be this discrepancy. 


We did that in the technical basis document by 


pointing out the difference between the 


recycled uranium study in 2000 and the one 


that was done in 2003 to explain why we 


defaulted to different levels than what was in 


2003. 


The 2003 document was important, but 


it was not complete in terms of defining all 


of the material flow, recycled uranium, 


because gaseous diffusion recycled uranium 


came in. There’s a lot of different sites, 


secondary sites. 


MR. CLAWSON: Well, I wanted to bring it up 


because --


MR. RICH: You’re right from a first-time 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

85 

reading. It can be a disconnect. 


 MR. CLAWSON: Well, and you start getting 


into a little of what Fernald actually did, 


and, you know, when you start looking at 


outside, even outside studies that were done 


by other groups, that -- I can’t remember the 


name, but they called the group that was just 


outside Fernald, the locals there. 


MR. ROLFES: Fresh. 


 MR. CLAWSON: Fresh, that’s what it was. I 


couldn’t remember. There seemed to be kind of 


a disconnect of part of this, and I just, 


mainly for clarification, we may look into 


that a little bit. We’re basing everything on 


urinalysis and bioassay. How many --


MR. RICH: For uranium. 


 MR. CLAWSON: For uranium. How many 


bioassays and uranium samples do we have? 


MR. ROLFES: Uranium urinalysis results? 


 MR. CLAWSON: Yes. 


MR. RICH: Several hundred thousand. We 


have a lot. 


MR. ROLFES: Off the top of my head I know 


that the latest number I had saw and reported 


at the Advisory Board meeting was about 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

86 

180,000 results. However, I believe there are 


some additional ones as well in HIS-20 that, 


so the number’s at least 180,000 results. 


DR. MAKHIJANI: Dr. Ziemer, just for your 


reference I was wrong about (inaudible). It’s 


Bogar 1986. 


DR. ZIEMER: It’s what now? 


DR. MAKHIJANI: The material accounting 


reference is Bogar, B-O-G-A-R, 1986. 


DR. BEHLING: Are we finished with this? 


 MR. CLAWSON: Yes. 


DR. MAURO (by Telephone): Before we leave 


that -- this is John Mauro. In listening to 


the discussion I’m thinking about something 


that Arjun mentioned earlier and I think we 


touched upon, but I’d like to hear a little 


more on an issue. Let me pose my question. 


Let’s say we have a worker, and we 


have a bioassay sample in terms of micrograms 


per liter. We have that information regarding 


him, and perhaps we have a number of 


measurements for that worker. And we need to 


reconstruct a dose to one of his organs. And 


what I’m hearing is that there’s some 


possibility that, well, we don’t know whether 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

87 

that worker predominantly worked with natural 


uranium or perhaps enriched uranium. I heard 


numbers as high as five percent. 


Also, there was some question about 


whether or not that material might have been 


recycled uranium that could contain ten parts 


per billion of plutonium. Where I’m going 


with this is something I guess I’m not quite, 


it’s almost more of an interpretation of the 


regs. If I have the worker, and I say, well, 


we’re really not quite sure whether he was 


working with a lot of enriched uranium or 


primarily for natural uranium and how much of 


it might have been of a particular chemical 


form and how much of it may have been 


recycled. 


In theory, in theory -- and I 


understand, Mark, what you had said. In 


theory, certainly, you could make assumptions 


that would maximize the dose in terms of the 


degree of enrichment, chemical form and 


whether it was recycled or not. Now, I guess 


I have an SEC question that I could use a 


little help on. 


Is it considered to be sufficient 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

88 

accuracy to say, well, we’ll default to those 


worst case assumptions when we really don’t 


know for this particular worker or there’s 


some uncertainty regarding this particular 


worker and what he did where he worked, et 


cetera, and just default to that which would 


drive his particular dose considerably much 


higher than, let’s say, if we knew exactly 


what he did, and we know the circumstances 


were different. 


So I think what I was hearing before 


when this matter of, is that considered to be, 


if you do take that strategy -- I’m not quite 


sure if, in fact, that’s the strategy you plan 


to use, but it sounds like you might be 


leaning that way. If you do take that 


strategy, my question, I guess, is one of does 


that represent an approach from the SEC world 


that would be considered sufficiently 


accurate? 


 DR. WADE: Maybe I can read from the SEC 


rule and I think it goes to your question, 


John. These things are always subject to the 


interpretation of the listener, but I’m going 


to read from 83-13.c.1. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

89 

Is it feasible to estimate the level 


of radiation dose of individual members of the 


class with sufficient accuracy, question mark. 


Small i, radiation doses can be 


estimated with sufficient accuracy if NIOSH 


has established that it has access to 


sufficient information to estimate the maximum 


radiation dose for every type of cancer for 


which radiation doses are reconstructed that 


could have been incurred in plausible 


circumstance by any member of the class or if 


NIOSH has established that it has access to 


sufficient information to estimate radiation 


doses of members of the class more precisely 


than an estimate of the maximum radiation 


dose. 


So, I mean, I think that answers the 


question, but again, you always have to leave 


that supposition to the ear of the listener. 


MR. ROLFES: These are plausible 


circumstances, and the issue of sufficient 


accuracy, we’re making compensation decisions. 


We’re not doing best estimates for regulatory 


compliance reasons. We are doing claimant 


favorable dose estimates for claimants. And 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

90 

when we have uncertainties associated with 


plausible circumstances, those uncertainties 


are always given to the benefit of the 


claimant in our dose reconstructions. 


DR. MAURO (by Telephone): And I, Lew and 


Mark, I appreciate that answer because I think 


you’ve answered my question. The answer is, 


yes, that since it’s plausible that this 


particular worker in theory could have handled 


as high as five percent enrichment for some 


period of time, and it could have been 


recycled uranium -- this is a hypothetical now 


I created -- and since all of those are 


plausible scenarios, if, in fact, they’re 


considered plausible, then even though the 


only information you have is milligrams per 


liter of uranium in the urine, it would be 


considered to be of sufficient accuracy and 


plausible to make these what I would call 


worst case assumptions since they do fall 


within the realm of a possible scenario. 


And I think you’ve answered the 


question. The answer is, yes, that would be 


considered to be sufficiently accurate. It’s 


something I’ve been thinking about, and I 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

91 

think I was looking for an answer. And am I 


correct? There’s a general consensus that 


that is a proper interpretation. That is, the 


scenario I just described would be considered 


to be, yes, that would be a reasonable way in 


which to deal with that particular worker. 


MR. ROLFES: I’m sorry. Could you repeat 


the question for me? 


DR. MAURO (by Telephone): Well, it just had 


to do with, you know, if all you have is 


fluorometric results in micrograms per liter 


urine analysis, and then you’re in a position, 


and this is more of an SEC question now. And 


I ask myself the question can I reconstruct 


this worker’s dose with sufficient accuracy. 


Now I have before me a lots of options 


of assumptions I could make because remember, 


my starting point is milligrams or micrograms 


per liter of uranium. And then I have to say, 


well, what am I going to assume is the type of 


uranium. In other words how do I convert that 


into activity. And I also want to factor in 


that where perhaps there may have been also 


recycled uranium or plutonium in there. 


And if we don’t know, we give him the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

92 

benefit of the doubt, and we assign that to 


him. And I could understand why that would be 


a way of making sure you’re claimant 


favorable. And my question was is that 


something that one would consider to be of 


sufficient accuracy for that worker. And I 


think the language that Lew just read says, 


yes, that would be considered to be within the 


definition of sufficient accuracy. And that 


was the question I asked. 


MR. HINNEFELD: I believe that would be 


NIOSH’s interpretation. 


DR. MAURO (by Telephone): Okay, I 


appreciate that. 


 DR. WADE: But again, it is also left to the 


Board to make its judgment of that 


interpretation when it makes a recommendation 


to the Secretary. There are four parts to 


what I read I think are important to remember. 


The one is that NIOSH as established has 


access to sufficient information to estimate 


the maximum radiation dose for every type of 


cancer incurred in plausible circumstance by 


any member of the class. 


So to go back to Arjun’s question, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

93 

there was a time when, Mark, you said for most 


members of the class. The test is for any 


member of the class. But I think when you 


look at the range of those tests, the Board 


then can understand what’s in front of it. 


DR. BEHLING: But, John, the question, I 


raised that very question that you were 


asking. And as a starting point I said, you 


know, what are the assumptions regarding 


solubility, enrichment, et cetera. And what 


you were basically asking which, for instance, 


five or seven percent in their documentation 


that seven percent enrichment was, in fact, 


used at least for certain periods of time in 


restricted quantities. Now, the question is, 


is a default value of two percent something 


that will satisfy your concerns, John? 


DR. MAURO (by Telephone): That’s why I 


asked the question, yes. And I heard that the 


selection was based on the time period you 


might use two percent. But then I also heard 


at the same time that there’s some evidence 


that there were time periods, or at least 


situations when the concentrations may have 


been as high as five percent. And I think 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

94 

that goes toward some judgment. In other 


words the judgment is, is it sufficiently 


accurate to assume a default of two percent --


MR. GRIFFON: Well, that’s, yeah, that’s 


where we have a (inaudible), I think. 


MR. ROLFES: Yes, if you take a look at the 


data the numbers of, in one of my slides I had 


from the approximately 12,000 drums that were 


stored in Warehouse 4-B I believe it was. If 


you took a look at the amount of material that 


was there, the great majority of that material 


was either depleted or natural uranium, 


approximately 76 percent of the material. 


Now, the other components that were in 


fact in that warehouse were between natural 


uranium and 1.25 percent. So between 0.71 


percent U-235 and 1.25 percent. And then 


there was another group of, I believe, 1.25 


percent up to two percent enriched. That was 


a very small quantity. So when you take a 


look at the mass values of the uranium that 


was processed, it’s very obvious that the 


great majority of the products coming from 


Fernald over time was natural or very, very 


slightly enriched material. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

95 

MR. HINNEFELD: But for SEC purposes the 


point is, is it plausible the members of the 


class, some employees, had an exposure, and if 


you’re going to break this down by maybe a 


year or whatever increment you’re going to 


talk about, that their exposure that year 


exceeded the two percent, some group, some 


small group of employees. That’s an SEC 


question. It’s completely irrelevant that the 


place dumps out mainly depleted uranium at the 


end. So that’s completely irrelevant to the 

SEC. 

What’s relevant to the SEC is, is 

there a way to demonstrate that some 


enrichment value -- whatever you choose. 


Right now it’s at two percent, but some other 


enrichment value, really provides an upper 


bound for what some small group of people 


might plausibly have been exposed to in a 


particular year if you want to break down by 


year. 


DR. MAKHIJANI: And that data request, the 


TBD is volume two on page 15, paragraph one. 


The current TBD in volume two on page 15 says 


that 1,500 (inaudible) mass batches of up to 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

96 

ten percent U-235 materials were prepared for 


drum digestion. And it also said this was 


recycled uranium. So we’ve got actually 


potentially, you know, an example of many 


batches of uranium over time from ’66 upward 


limit possibly of the uranium enrichment plus 


recycled uranium contaminants. 


Do you have examples of worker DOE 


files that contain information that said which 


workers worked with this data. Now, this is 


in the refinery I think. Which workers were 


in the refinery or whether maintenance workers 


who went there to do this work, it is in their 


records. So some way of identifying the 


workers who worked with these 1,500 batches of 


ten percent. 


MR. ROLFES: This operation they used 


material of up to ten percent enrichment to 


sweeten other batches of uranium metal. We 


know where this operation was conducted, and 


some of the interviews that we conducted were 


focused on this specific issue. 


We know that some of the air 


monitoring data that we have from this area 


has documented higher enrichments of material. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

97 

And it also does have employees’ names but not 


consistently. So we will have to take a look 


at that area and the exposures associated 


with, well, potential exposures to high 


enriched material in those areas where they 


did the blending. 


DR. MAKHIJANI: I guess you missed my 


question. The question was can you give us 


examples of DOE employees’ individual files 


that would establish that you know who worked 


with this material or would the proposal then 


be to assign everybody if, you know what I 


mean? If you were in that SEC mode, you have 


to be able to identify the workers who got, 


who worked with ten percent recycled uranium. 


DR. ZIEMER: I think he’s saying they’re 


going to go back and look at that issue. 


DR. MAKHIJANI: So it would be useful for us 


just as an action item, if the working group 


agrees, it would be useful for us to have 


claim numbers or employee files that contain 


information about who worked with this. Or in 


the alternative --


DR. ZIEMER: There’s the other side of the 


question you’d have to ask, and that’s can you 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

98 

show somebody didn’t work with it. I think 


for the SEC you have to be able to establish 


that either on a time basis or a location 


basis probably. 


DR. BEHLING: Can I just make a comment 


here? In finding number four I included 


excerpts from a Health Protection Appraisal 


report dated September 1968. And it states 


here that action has been initiated for 


hanging Uranium-235 enrichments about five 


percent, current plans include installation in 


Plant 1 of a continuous digester for 


enrichments up to ten percent. 


And on the next page it makes 


reference to significant portions of the fuel 


will range from three to seven percent U-235 


enrichment. And so there are documents here 


that lead you to believe that up to at least 


seven percent and possibly ten percent 


enrichment was processed at Fernald. 


 MR. CLAWSON: Excuse me. Go ahead. 


MS. BALDRIDGE: I’ll identify, Sandra 


Baldridge, a petitioner. I have a question. 


You stated that about 180,000 pieces of 


uranium urinalysis data. Of those data, is it 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

99 

identified which of those are from employees 


who had renal damage who would be retaining 


certain levels of uranium that were not being 


excreted? 


People with exposure to uranium 


hexafluoride in one of the documents submitted 


showed everybody who had that exposure had 


renal damage. Now when I was going over my 


father’s papers, I noticed in his medical 


infirmary records that there was a notation 


that he had renal damage. When I checked 


online about the condition and so forth it 


says that that type of renal damages causes a 


retention of uranium salts. 


So if you are assuming that everyone 


was excreting at a hundred percent efficiency 


rate for the kidney, you know, and someone has 


a 50 percent or 70 percent or 80 percent 


damage, you don’t know what their retention 


rate is so to measure what their excretion is 


and assume their dose based on that, you are 


eliminating the potential for undetected 


exposure and dose. 


MR. ROLFES: Well, I’d like to clarify. If 


we suspect that the urinalysis data might not 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

100 

be adequate, we are developing a coworker 


intake model based on urinalysis data for the 


entire plant. The urinalysis data is not the 


only bioassay data that we have. We also have 


lung count data which we could use. We could 


take a look at the intakes that we’re 


assigning from the urinalysis data and then 


compare those intakes to the intakes measured 


by the chest counter at Fernald. So that we 


wouldn’t have any indication that --


MR. GRIFFON: Chest counting wouldn’t be 


until a later period. 


MR. ROLFES: Until 1968, that’s correct. 


There are indications in reports of 


renal damage that occurred from exposures to 


uranium hexafluoride, and that’s, in fact, why 


uranium was being monitored for in order to 


control people’s urine concentrations below a 


standard level to prevent nephrotoxicity. 


Have I answered what you’re asking? 


MS. BALDRIDGE: I think it just shows that 


even the data you’re using can’t give a 


definite comparison unless you know how many 


of these people were only excreting a portion 


of what they were being exposed to. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

101 

MR. ROLFES: When we’re actually using the 


solubility that is the most claimant 


favorable. So --


MS. BALDRIDGE: Solubility doesn’t reflect 


excretion --


DR. ZIEMER: I think it’s an interesting 


question. I don’t know that any of the 


models, the ICRP doesn’t take that into 


consideration, and it seems to me it’s an 


interesting question. Somebody ought to look 


at it. I think it’s an --


 DR. WADE: Well, I think it’s a very 


interesting question. 


MS. BALDRIDGE: I wouldn’t have realized 


that it was a problem if I hadn’t been --


 DR. WADE: Yeah, excellent question. 


DR. ZIEMER: I don’t know if we have a way 


to handle that, but certainly --


MR. GRIFFON: I think the fundamental answer 


to your, the first part of your question, 


right now the data that you have, you don’t 


necessarily have anything that implies that 


the person had renal damage, I’m pretty sure. 


MR. ROLFES: Well, there are some reports 


that have documented some overexposures to 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

102 

uranium hexafluoride in the early time period. 


DR. ZIEMER: Would that be in the medical 


record of the claimant? 


MR. ROLFES: It is, in fact, documented in 


some reports. I do not know if it would be 


provided to us within the DOE dosimetry 


response. 


MS. BALDRIDGE: My father’s records didn’t 


show that he had an overexposure. It just 


showed up and said, well, obviously he has 


been exposed to it at some point that has 


resulted in this damage. So it wouldn’t have 


flagged his file to say there’s been an 


incident here where this man was exposed. 


This was something that occurred without their 


knowledge, and they, after the fact, put the 


pieces together. 


MR. ROLFES: The deterministic effects from 


uranium exposure associated with uranium 


hexafluoride, uranium hexafluoride is one of 


those more soluble compounds. And when we 


would do a dose reconstruction, it could 


affect, you know, an injured kidney could 


affect excretion. However, the material is 


generally a very soluble material. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

103 

So, in fact, that material rather than 


being excreted over a few day period, could be 


excreted over say a week or a month period. 


So it may extend the period which the uranium 


is being cleared from the body. And it’s 


likely something that we definitely, I’d have 


to take a look at the case and the urinalysis 


data in order to make a judgment about a 


situation like that. 


 DR. WADE: I think it’s a valid issue that 


needs to be addressed and reported back to the 


work group. 

 MR. CLAWSON: And you’ve written that down, 

Mark? 

MR. GRIFFON: Yeah. 

 DR. WADE: Thank you. 


DR. ZIEMER: Can I follow up briefly? 


MR. GRIFFON: It might have wider ranging 


affects, too, on other sites as well. 


DR. ZIEMER: On the issue of the discrepancy 


on some of the source terms, the reference 


that Arjun mentioned references by Bogar ’86, 


it’s a document in a litigation file. I just 


want to ask, is that available --


DR. MAKHIJANI: I will call the law firm and 

1 -- 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

104 

DR. ZIEMER: It’s a Cincinnati law firm. 


DR. MAKHIJANI: Or you can call them. I 


mean, it would be better --


DR. ZIEMER: I mean, it’s a reference, but 


it’s not clear that it’s available. 


MR. RICH: Did that come out of a class 


action suit? 


DR. MAKHIJANI: Yes. 


MR. HINNEFELD: That’s from a class action 


suit, but I mean, that reference in that time 


period should be available from Fernald. We 


should be able to get that from DOE. 


DR. MAKHIJANI: I believe there’s a full set 


of documents every year -- and Stu would know 


that better than me -- every year there was a 


report filed at least once a year. And I 


think at some period there was a monthly 


report that was filed. It contains DU, NU and 


EU. I don’t believe it actually contained to 


my memory the level of enrichment. But it 


does specify the three screens and quite 


specific and quite detailed. 


MR. HINNEFELD: Yeah, there was production 


control. There were, you know, routine 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

105 

production controls. 


DR. ZIEMER: But they have access to 


different documents than you did? 


MR. HINNEFELD: This document here, this 


Bogar document should be available from the 


Department of Energy. That’s got to be 


available from the Department of Energy. 


That’s, so that’s got to be available. 


DR. MAKHIJANI: That’s not the only document 


that the lawyers got from DOE. 


MR. HINNEFELD: Yeah, I know the author or 


knew the author. 


 MR. CLAWSON: Okay, well, one of the perks 


of being the Chair, I think we need a comfort 


break. For those on the phone we’re going to 


take a ten or 15 minute break, and then we’ll 


resume. 


 DR. WADE: Just stay on the line so we won’t 


break contact. 


(Whereupon, the working group took a break 


from 10:05 a.m. until 10:25 a.m.) 


 DR. WADE: Ready to go, so please --


 MR. CLAWSON: Has it been unmuted? 


 DR. WADE: Yes, it’s unmuted. 


 MR. CLAWSON: Is there any more discussion? 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

106 

One of the requests that’s come up to me as 


the Chair is that there’s a lot of issues we 


need to try and get through, but we don’t want 


to miss anything in the action. I feel that 


the first finding, there’s been several 


addressed. But before I proceed on I would 


like to review the action items, if we could, 


Mark, and just make sure that we’ve got 


everything down. 


MR. GRIFFON: You want to do these that we 


do so far? 


 MR. CLAWSON: Yeah, just before we go on to 


the next one because we had several issues. 


MR. GRIFFON: Yeah, I have seven issues 


actually. NIOSH to review assumptions on 


enrichment level. This is all related to 


action item finding number one so it’s related 


to uranium. Second, SC&A to provide 


references regarding enrichment levels. Bogar 


1986 I think is the one --


DR. MAKHIJANI: Now is Stu going to get that 


from DOE? 


MR. HINNEFELD: We should be able to get 


that from DOE. If we have a problem, I’ll let 


you know. But I don’t see how we cannot get 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

107 

that from DOE. 


DR. ZIEMER: And the reference is in the 


SC&A report. 


MR. HINNEFELD: It’s a Bogar ’86 document. 


I don’t see how DOE cannot have that, but 


we’ll try to get that. 


MR. GRIFFON: Okay, so NIOSH to get this 


reference I think is the way I’ll say that. 


Third is NIOSH to provide sample DR to 


demonstrate approach for doing internal DR for 


uranium. That was what Mark had brought up. 


MR. ROLFES: Mutty, do you know, do you 


recall -- I haven’t looked at the sample dose 


reconstructions that we completed. We may 


have already done something very similar for 


uranium. 


MR. GRIFFON: You can review it. See if 


they meet that. 


The fourth one is NIOSH to examine 


whether the approach is appropriate for all 


members of the class. Parentheses, is there a 


subset of workers or areas where different 


assumptions should be made is the question of 


your sample. Does it fit all? As we’ve said 


all members of the class. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

108 

DR. MAKHIJANI: Could I supplement that in 


terms of the request for specific worker data? 


MR. GRIFFON: Well, I have that, I have that 


in another action. I just kept them 


sequentially so they might overlap a little 


bit. 


Five is NIOSH to review the total 


production numbers for uranium, provide -- and 


I think Bryce provided a good response to 


this, but maybe a written response, provide a 


written response to clarify differences in 


numbers in the TBD versus other documentation. 


Write it out. 


MR. RICH: We can address the expected 


discrepancies and for what purpose. 


MR. GRIFFON: Six was NIOSH to provide claim 


numbers for workers that worked in the 


blending areas, I said, involving the high 


enrichment levels. Is that where you said 


you’d like to see some of the high enrichment 


levels? 


MR. ROLFES: We definitely have air samples 


identified with individuals’ names on them. 


It might take a little bit of work to, because 


somebody might have been monitored that isn’t 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

109 

a claimant so we’ll see what we can do to 


respond to that. So it may not be claim 


numbers --


MR. GRIFFON: You may come back and say we 


couldn’t find any claims that fit in it. 


MR. RICH: Define the operations associated 


with the high enrichment. 


MR. ROLFES: Yes, exactly, exactly. The 


process information we can get, the additional 


information can be provided on --


MR. RICH: Which is not directly related to 


dose reconstruction although it has some 


implications. 


MR. GRIFFON: And the last one is NIOSH will 


examine the issue related to renal failure and 


the effect on uranium excretion and on the DR 


approach. And that was one of the same. 


 MR. CLAWSON: Well, one other thing I’d like 


to request from NIOSH, and I know this isn’t 


onto this, is yesterday we came up with one of 


the things. These TBDs and so forth, when we 


add pages and so forth like that, could we 


kind of highlight those so that we know where 


they went, where they were placed in there? 


Because for us to feed through, like we did at 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

110 

the Nevada Test Site, what areas were changed 


or so forth --


MR. ELLIOTT: A matrix, you want a 


specification of where we made the change in 


the document. 


 MR. CLAWSON: Yes, if you would. That’d 


just make it a little bit --


MR. ROLFES: Sure. I understand for like a 


page change. I think our internal dose 


section is going to be, it’s going to have so 


much additional supplemental information from 


three years ago, I think it would be a 


significant amount that would be highlighted, 


so --


 MR. CLAWSON: Well, yeah, just, like we did 


with the Nevada Test Site where they were 


changed --


MR. ELLIOTT: It will simply say the section 


number. 


 MR. CLAWSON: And so forth like that, I’d 


appreciate it. 


MR. ELLIOTT: Sure. 


 MR. CLAWSON: Arjun, if you want to continue 


on with --


DR. MAKHIJANI: I think Mark has already 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

111 

covered what I have. 


 MR. CLAWSON: Hans? 


QUESTIONABLE INTEGRITY OF FLUOROPHOTOMETRIC URINALYSIS 


DATA
 

DR. BEHLING: Yeah, let’s just go to the 


next finding, and the finding that you may see 


in your matrix is simply identified as 


questionable integrity of the 


fluorophotometric urinalysis data. 


And we’ve already discussed the limits 


of it based the fact it only gives you 


quantities rather than isotopic (inaudible). 


But in addition to that there is something of 


a near absence regarding formal records that 


define the protocols that were used or any 


quality showing some quality controls that 


were exercised to ensure that the data was, in 


fact, reasonable and scientifically sound. 


But one of the things that also 


bothers me is the issue of how the people who 


actually ran the program perceived urinalysis. 


And let me quote a couple things that came 


from people who were in charge of the program, 


and what their statements were in memos. And 


I’ve identified these memos as part of the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

112 

attachments. 


I won’t go identify the names because 


we’re trying to obviously shield people from 


being identified here, but they are reputable 


sources. And he says, “We use urinary uranium 


excretion information along with air survey 


information to be sure that we are controlling 


airborne exposures to amounts that will not be 


harmful.” 


And then he goes on to say, “We do not 


consider the urinary uranium excretion 


measurements as an accurate method for 


estimating either body burden or any method 


for exposure.” And it goes on and on. And 


there are several of these documents that 


consistently make reference to that. 


On another date the statement goes on, 


“We have pointed out on previous occasions we 


have little confidence in the reliability of 


any method for assessing dose from depleted, 


normal or recycled enriched uranium as 


levels,” et cetera. “...and believe that 


uranium assay results are of no value for this 


purpose.” And there’s on and on. 


I’d cite multiple documents by people 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

113 

who represented the Industrial Hygiene and 


Safety who claim that they have little or no 


faith in urine data, but it was really a 


screening technique for ensuring that the air 


concentrations. So it’s almost the reverse of 


how we perceive the data for doing dose 


reconstruction. NIOSH at this point is 


looking at urine data as the principle means 


for dose reconstruction and essentially 


ignoring air concentration data. And here the 


people whose job it was to essentially monitor 


people who say we have no faith in it. It’s 


useless. 


Now, I realize there’s still 


information out there that says we have John 


Doe’s urine, and it contains 300 micrograms. 


And if one could reasonably conclude that 


these assays were done with meticulous 


precision and analytical protocols that we 


can, at this point, look at, yes, they’re 


useful. 


But when I read these statements by 


the very people who were in charge of the 


program who actually questioned the usefulness 


of this data, then I have to question to what 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

114 

extent were the technicians informed you will 


do this based on this procedure. You will do 


this accurately. You will calibrate your 


instrumentation, et cetera, et cetera. 


It gives me a very less than warm 


feeling about the accuracy of data when I read 


these comments that this data is virtually 


useless. And I bring that up because it’s 


repeatedly stated in these documents. 


DR. ZIEMER: Let me ask a question related 


to that because part of this may have to do 


with time period. One of the issues on use of 


data is always the model. Models have changed 


over the years. We can take the same data now 


and get much better output than people could 


in the ‘50s and ‘60s. 


So I’m sort of asking the context of 


the statement. Are they saying that we don’t 


trust the data or we don’t have models that 


are good enough to take the data and predict 


body burden? Which 40 years ago I would have 


made a statement of that sort, too. I’m 


trying to get a context --


DR. BEHLING: I agree. It’s a little bit of 


both that obviously they didn’t have the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

115 

benefit of current ICRP models that would say, 


okay, based on excretion and various 


assumptions we can now back-fit this and 


essentially identify what the body burden is 


and do dose modeling. I agree with you, Dr. 


Ziemer. 


But the question also is if you don’t 


have that level of usefulness, which they 


clearly did not, then the question is to what 


extent did that affect the technicians in the 


laboratory running these assets? And I think 


you have a combination of effect. They didn’t 


have much use for it because the ICRP models 


didn’t exist. 


But on the other hand their limited 


use may have impacted their sense of 


importance that will come in the year 2007 


when NIOSH will then look at the data and say, 


you know what, that’s the best we’ve got, and 


let’s use it. The question is did they have 


that understanding that some day, maybe, some 


day we would make use of this and we better be 


very good in doing what we’re doing even 


though we at this point can’t interpret it. 


And I just raise that as an issue. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

116 

DR. MAKHIJANI: One additional point, Dr. 


Ziemer, about that. This is on pages, page 


27, 28 of SC&A review. And this is throughout 


the period. I think the latest document that 


Hans has cited is from ’84 --


DR. BEHLING: ‘Eighty-four. 


DR. MAKHIJANI: -- where it says, “Excretion 


urinalysis data recorded, but this cannot be 


used for calculating internal dose.” So it’s 


not post-ICRP-60. But it’s fairly recent. 


MR. HINNEFELD: If I can offer. This was 


the historical opinion of the people who ran 


Fernald who were still running Fernald in 


1984. And in point of fact the DOE order 


which was the equivalent of the regulatory 


requirement at this time didn’t really require 


you to do dosimetry from your bioassay 


program, and Fernald didn’t. 


So the fact that it goes into 1984, I 


don’t think you should read too much into 


that. The really good models came out in ’76, 


you know, the 30, the real change in the model 


from ICRP-2 where you could really make some 


judgments about where the uranium ended up 


came out in ’76. Didn’t make it, you know, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

117 

Fernald by ’84 had not adopted using that and 


didn’t make it into the regulatory scheme at 


DOE until I think about ’89. 


So this reflects that attitude of with 


ICRP-2 which is what your requirements tell us 


to do. We can’t do this. So that’s it. Now, 


that’s the point. That explains the 


timeliness of it. Han’s point is interesting 


is if they felt like this was a screening were 


they that careful. Were the analysts that 


careful? I don’t know what exists of the 


records or of the operations and procedures 


from that period. I don’t know if anything 


exists from that period. 


MR. GRIFFON: I think that may --


MR. HINNEFELD: It pre-dates me, you know, 


if you get back before, probably before ’83. 


I started in ’81, but I didn’t really work in 


radiation detection until ’83, from that time 


forward the people who ran the laboratory were 


pretty conscientious about giving a good 


laboratory result. Tom Dugan, who ran the 


lab, is still alive and lives in the area, and 


they were pretty conscientious. 


DR. ZIEMER: Well, you know, even there, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

118 

there’s no reason why a technician would 


suddenly say, well, I don’t have to use care 


in counting. I go back to the, most of you 


who have been in Health Physics have done 


smears, thousands of smears over the years. 


And we all know that smears have almost no 


analytical value, but they’re always carefully 


counted. 


MR. RICH: To the second decimal place. 


DR. ZIEMER: Yeah, even though they’re 


simply indicators. There’s no -- it seems to 


me it doesn’t make sense to say -- we never 


had this situation where, well, I don’t care 


what the count come out because it’s not that 


accurate or something. You always counted it 


carefully and got your statistics. 


MR. RICH: There’s one more issue, too. 


This is Bryce Rich. In the very early days 


the urine samples were rigorously and 


religiously taken because the controls were 


based on a toxicology basis. They used those, 


and they restricted the people from the work 


place on the basis of meeting certain criteria 


from a toxicology standpoint. They were very 


careful. And they were used for that purpose. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

119 

And the fact that they were going to 


be used later for radiological determinations 


was not a consideration for them at that 


point. They didn’t anticipate that they would 


use them for radiological dose determinations. 


And so I’m not surprised, as Stu indicates, 


particularly in later years, they were still 


expressing doubt that they could be used 


accurately for dose determinations. 


DR. BEHLING: I just raised it as an issue 


that may define a wider margin of uncertainty 


with regard to the accuracy of such data. 


MR. RICH: And just one more thing. We’ve 


talked to professional people associated with 


the analytical work that was done at that 


time. They started in ’54. They started in 


’54 at the very earliest, and they are quick 


to say that they were, they had procedures. 


They were detailed procedures at the outset, 


and we’re in the process of trying to recover 


some of those very early documents. That’s 


tough to do, but they had, there were 


procedural (inaudible) as a matter of fact. 


So they were very disciplined in what they did 


-- at least from our interviews -- just 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

120 

yesterday. 


 MR. CLAWSON: Well, I’d like to bring up one 


because everybody’s brought up something. 


There’s always the human factor in everything, 


but what Hans has brought up because I know it 


still today. There are readings that I take 


that are totally bogus, and they offer nothing 


to the process. But it’s to what point of 


enthusiasm do I do them. It’s like a cast to 


be able to get out. I’ve watched them 


(inaudible) that things many times and take 


two days to get out of there. 


But when we’re up against the gun 


watch them take one swipe and not even count 


it and you’re going out the door. I think 


this is what Hans is kind of bringing up is 


when you’re taking bogus data, to what level 


do you really go to. And I’m not saying that 


they did or anything else, but it’s something 


that we need to kind of think about, too, and 


what their comments are. 


MR. ROLFES: For example, to sort of address 


what you said if the lab observed an unusually 


high result, an unusually high urinalysis 


result, they would have typically prompted 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

121 

that with a follow-up bioassay request to see 


what the problem might have been and determine 


whether that first sample was, in fact, valid 


or not. 


DR. BEHLING: This is the bioassay. You 


mean a second bioassay. 


MR. ROLFES: Yes, a second bioassay. 


MR. SCHOFIELD: Do you know how often these 


bioassays were actually done on the workers? 


MR. ROLFES: Yes, anywhere from daily, 


multiple times per day, up to annual for 


people that were working outside of 


radiological production areas. 


MR. GRIFFON: This gets into --


 MR. CLAWSON: This gets into a lot of 


different things. We could debate this one 


for about a week, but let’s -- Hans, if we 


could --


DR. BEHLING: And as I said, I don’t expect 


any action things. Just sort of a mental note 


that says don’t always believe everything or 


assume 100 percent accuracy. Consider the 


fact that the likelihood is that uncertainty 


margin is maybe wider than you would like to 


believe. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

122 

MR. GRIFFON: Well, I do see some actions 


here maybe. I just want to reflect back to 


the Board procedures on SEC reviews, and one 


thing that we specify is data integrity. So 


this gets a little off your finding, but the 


question of, earlier I think you said that we 


have yet another HIS-20 database out, uranium 


data. So I would ask that be one action is 


that’d be posted. I mean, I mentioned it 


before, but now that we’re capturing all, and 


if you could just post all that data, that 


would be very useful. 


The other question I think we have to 


examine to some extent anyway is the issue 


that comes up at many of these sites from 


workers that we’ve heard testify again and 


again is just the question that you kind of 


alluded to, Mark, is that, you know, I went in 


and I had a real high urine sample. And they 


said, oh, it must have been a contaminated 


sample. We need to follow up. We’ll take a 


follow up, and that’s the one that gets in the 


record and that high one went away. I think 


we need to verify that that kind of thing 


didn’t happen. That the data integrity is 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

123 

good from that standpoint. 


MR. ROLFES: We have no indication to, there 


have been reports indicating that, you know, 


samples could have been contaminated, but we 


generally see those in peoples’ records. I 


don’t believe there’s any indication. I don’t 


see proof in front of me that, but it is 


something we’ll take a look at. 


MR. GRIFFON: The one way certainly to 


examine this is if we have laboratory logbooks 


along with the database and all the records 


show up in both. Then we’re, you know, then 


everybody’s comfortable that those values 


weren’t dropped. 


DR. ZIEMER: What year did we start to get 


other kinds of bioassay, this whole body 


count? 


DR. BEHLING: ‘Sixty-eight. 


DR. ZIEMER: So that’s much earlier than in 


’84 when people are still not confident. I’d 


like to see can you cross-calibrate and say, 


okay, can you confirm -- maybe you’ve done 


this -- lung data and bioassay --


MR. RICH: In your comment, when they 


started to take lung count as a bioassay 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

124 

method, they did establish percent of maximum 


permissible lung burden for a period of time 


based on lung counting data and did 


restriction of workers on that basis in 


addition to the toxicological determination 


from urine sample data. 


DR. ZIEMER: But they should be able to 


cross-calibrate those. 


MR. RICH: Yes, yes. And they also did 


their AEC reporting on the basis of 


radiological issues in terms of maximum 


permissible. 


DR. ZIEMER: I think, Mark, on the integrity 


issue perhaps at least on those points or 


those later ones where we have both kinds of 


data, that would help us. It doesn’t 


definitively speak to the early years, but at 


least if there’s some indication that there’s 


consistency between urine analysis and other 


types of internal assessments, it would be 


useful it seems to me. 


MR. MORRIS: I transcribed a lot of that 


data, that lung count data, in order to use it 


in an electronic format. And there are 


probably 90 to 95 percent of the people who 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

125 

had unremarkable lung count. There might be 


five percent or fewer that had many lung 


counts in the same year, and they were 


obviously --

DR. ZIEMER: They were tracking something, 

yeah. 

MR. MORRIS: -- tracking some specific 

intake. I would think it would be completely 


useless to follow the 95 percent of the people 


who had one lung count a year. 


DR. ZIEMER: Oh, yeah, I wasn’t suggesting 


you track all these people. I would select a 


few and see if you get correlation between 


urine analysis and lung data. 


 MR. CLAWSON: And I think also the procedure 


for the urinalyses and how they were done, and 


I know at a couple of the other sites with the 


earlier lung counts I remember that they used 


a different type I believe, that come up to be 


a little bit of a problem, but maybe these are 


some of the things we may be able to look into 


on that. 


Is there anything else, Hans? 


DR. MAKHIJANI: Yeah, I had a problem. I 


tried to do some of this stuff in relation to 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

126 

Fernald, and the complication you run into in 


the lung counting data and correlating it with 


the bioassay, of course, was the solubility. 


And they had all kinds of solubility at 


Fernald, and one thing that I found useful is 


to take the air monitoring data from a plant 


and to focus on workers, in the example you’re 


doing, to focus on workers in a particular 


plant at a particular time so that you have 


three different pieces of information. And 


that --


DR. ZIEMER: The urine, the air sample and 


the lung. 


DR. MAKHIJANI: -- and that I believe will 


give you, you know, within a factor of two, 


some confidence that you’re in the right 


ballpark. It doesn’t resolve all the issues. 


MR. GRIFFON: These kind of reality checks. 


DR. MAKHIJANI: Yeah, look at this as a 


reality check. 


MR. GRIFFON: Do you even have any kind of 


air sampling data database? 


MR. ROLFES: Database? No, but --


MR. GRIFFON: Do we have raw? 


MR. ROLFES: Most of it is raw data. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

127 

MR. GRIFFON: So it may be an uphill battle 


to use that as a comparison. 


MR. RICH: Most of the air sampling data is 


uranium. 


DR. MAKHIJANI: Could we ask for the 


interview documentation also because a number 


of interviews are being done, and it could be 


useful for us. I mean, just as an action 

item. 

MR. GRIFFON: That would cover a lot of 

these. That wasn’t just related to this. 


DR. MAKHIJANI: No, the prior referenced 


interviews but also (inaudible) interview. 


MR. RICH: And they’re all, Arjun. But they 


will be formally documented. 


MR. GRIFFON: Maybe that’s a general action 


item. 


 MR. CLAWSON: Go ahead. 


MS. BALDRIDGE: I would like to bring up the 


point when I reviewed my father’s records, I 


noticed that he had approximately 55 


urinalysis tests done. When I looked at the 


uranium urinalysis sheet that was provided 


with his files only 21 of those test appeared 


on that sheet. I had asked Mark if he knew 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

128 

why they would have been testing and not 


recording, and he didn’t have an answer. 


MR. ROLFES: That’s correct. Yeah, we did 


discuss that. And I don’t know what Privacy 


Act concerns I have here Larry about 


discussing specifics of her father’s claim. 


DR. ZIEMER: Well, why don’t you discuss it 


in general terms. What would you do in a 


case, or do you use all the data points. 


MR. ROLFES: Within the medical records that 


were kept at Fernald, there were blood tests 


that were taken for reasons other than for 


determining uranium concentrations. There 


were also urine samples that were provided 


during annual physicals where they would take 


characteristics of the urine other than for 


radiological or chemical analyses. They would 


take a look at white blood cell count to 


determine if there was any concerns about the 


person, if they had any kidney problems which 


would me like, for example, they may have a 


urinary tract infection. And in that case 


they would find white blood cells in the 


urine. For lead being excreted they would 


find red blood cells. There were also casts, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

129 

and based on the different types of casts and 


specific gravity of urine, they could infer 


different medical things. Those wouldn’t be 


indicative directly of radiological exposures 


and wouldn’t be used by NIOSH. Those also, I 


don’t believe, are routinely reported to 


NIOSH; however, the uranium urinalysis results 


are. That is one of the differences between 


the medical records that you received as well 


as the dosimetry records. 


FAILURE TO MONITOR ALL PERSONNEL WITH POTENTIAL
 

INTERNAL EXPOSURE TO URANIUM
 

DR. BEHLING: Let me go on to finding number 


three, and if you have a hard copy on your 


computer, I mean an electronic copy, it’s on 


page 28 of the report. And just briefly the 


finding is failure to monitor all personnel 


with potential internal exposure to uranium. 


And in Section 7.2.1.2 of SEC Evaluation 


Report from NIOSH it stated that nearly FMPC 


workers were monitored for uranium in urine. 


No coworker analysis has been deemed necessary 


for uranium intakes. 


So in the context of that statement I 


looked at some of the documents that were part 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

130 

of the petition, and in one of the attachments 


that I included was one in which -- this was 


dated May 13th, 1955 -- and it is a memorandum 


that was issued that involved urinary uranium 


investigations and involved four individuals. 


And I looked at the data and just as a 


background urine results that are greater than 


0.025 milligrams per liter would, according to 


the people who were running the program, would 


suggest that there was a moderate uranium 


exposure. And at levels of 0.04 milligram per 


liter these are considered in their terms 


excessive exposures. 


Well, when I looked at these 


individuals, one of them had 0.543 milligrams 


which is 13 times higher than what is 


considered an excessive exposure, and it 


involves a person that was described as a 


person who had little or no possibility of 


being exposed to uranium. And they provide no 


other information. 


And that first question that would 


come to mind is why were they even monitored, 


and that is an unanswered question. But under 


worst-case assumption they may have been 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

131 

monitored as a way of getting control values. 


Maybe they should have selected spouses of 


people or members of the general population, 


but it’s also possible that these four 


individuals, none of whom had reasons to have 


any uranium in their urine, may have been 


asked to submit a sample as a baseline that 


says, this is what ordinary people excrete 


based on consumptions of foods that may 


contain trace amounts of uranium and this is 


what we may even subtract from those who are 


workers in order to get a net value. 


I have no idea what these people 


represent. All it stated in the document is 


that there was no justifiable reason for them 


to have uranium. Now whether these were 


people who were exposed to fugitive emissions 


around the plant from contamination, I don’t 


know. 


But it’s disturbing to me to read that 


there were four individuals in a single memo 


that had concentrations 13 times higher than 


the 0.04 milligrams per liter that is 


considered excessive. And at this point I 


have no explanation as to what to do with that 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

132 

data other than assume that they were people 


exposed who were probably not monitored. 


That’s my conservative assumption. 


MR. ROLFES: Sure. So would definitely in a 


dose reconstruction, that’s why we are 


assembling a coworker model for coworker 


intakes now. And these intakes are, excuse 


me, these urinalysis data are documented. And 


so if we have those in a file, we would use 


those to estimate an intake of uranium. And 


even if it was a false positive, if we have no 


information but we have the urinalysis results 


such as this, we may not know the reason that 


this high bioassay result occurred, but we 


would assume that it was, in fact, a valid 


sample and assign an intake based on these 


data. 


DR. BEHLING: That’s clear for this person, 


but for every person that was serendipitously 


diagnosed with uranium in the urine, there may 


be people for whom there is no data. 


MR. RICH: Can I offer some operational 


experience? It’s not unusual in a large 


operation when you’re sampling a lot of 


different people to have some false positives 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

133 

for one reason or another, cross-contamination 


or a glitch in the laboratory. And then this 


stimulates an investigation. 


And I would interpret this memo as one 


of those, as an investigation of some unusual 


air samplings which would normally call for 


re-sampling and an investigation of the work 


place. And they say we don’t have any idea 


why this person would have, deliver that kind 


of a urine sample. 


So after re-sampling and evaluation, 


you go to your laboratory to see if there’s 


contamination or, you know, that would give 


you an indication how to look at your 


laboratory. This is not unusual in a standard 


operation situation. 


DR. BEHLING: I’m just looking at the first 


sentence here that says the following urinary 


uranium results were investigated first 


because there were no apparent reasons for the 


high uranium results. So something triggered 


this investigation. 


MR. MORRIS: An annual physical would have 


prompted the --


MR. RICH: Everybody gave a sample. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

134 

DR. BEHLING: Yeah, but that would be very 


disturbing to me as a result of an annual 


physical for people who were not radiological 


workers who would have --


MR. MORRIS: That is evidence of quality 


assurance. You know, they may not have called 


it that contemporarily, but it was evidence of 


a self-assessment going on. 


DR. MAKHIJANI: That might be an 


explanation. There could also be a different 


explanation. I think that fugitive emissions 


at Fernald were very high, and they’re not 


covered by your environmental TBD. We pointed 


this out in our review of the one that was 


published. The one that we reviewed. 


Essentially, 5.1.3 we talked about 


thorium fugitive emissions, and this is from 


1970. The worst housekeeping problem in the 


facility was in the mill. Equipment leaks 


excessively at practically every joint. And 


they had a kind of bucket brigade over there 


catching the stuff in buckets. Perhaps they 


had quality control in taking your example, 


but they didn’t have quality control in 


maintaining the equipment certainly. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

135 

And this is not the only example of 


its type. In the petition, and I pointed this 


out several times in various situations for 


the last two years, that Fernald has the 


distinction of having had a job that actually 


was done that had 97,000 time maximum 


allowable concentration averaged over that 


job. And in the next year it included the 


16,000 time maximum allowable concentration. 


This memo is in the SEC petition. 


Please do look at it, and these kind of 


operations were into the area of plausibility, 


could certainly give you plausible high 


exposures. And it’s plausible that it could 


be the kind of issue we’re talking about, 


cross-contamination and all that. But it’s 


certainly at least equally plausible that it 


would be fugitive emission exposure, 


especially -- well, this is a 1970 memo, and 


we all know that conditions, and there’s ample 


documentation that conditions in the ‘50s were 


far from sanitary, let’s say. 


It’s documented very, very amply, and 


I think the 97,000 time MAC is actually, if I 


remember right, maybe from around 1960. So 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

136 

this stuff extends into time, and I don’t 


believe that you can assume that non-monitored 


personnel had less than the average exposures 


because 97,000 times MAC is an annual exposure 


in 1.2 minutes. 


MR. ROLFES: Once again, for uranium 


exposures what we are relying on is the 


bioassay data within the person’s file. 


That’s the most important thing that we have. 


In greater than 90 percent of the people that 


we have in our claimant population at NIOSH 


for whom we need to do a dose reconstruction 


for have bioassay data within their file. And 


for the unmonitored, I believe it’s about 


seven percent. So seven percent may not have 


bioassay data, and that is why we are, in 


fact, developing a coworker intake model to 


address unmonitored exposures. 


MR. HINNEFELD: Do we know if the people 


cited in that memo are claimants? If any of 


them are claimants? 


MR. ROLFES: The names were redacted when 


they were provided to us so --


MR. HINNEFELD: So we don’t know then. 


MR. ROLFES: We would have to take a look to 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

137 

find out whether they are, in fact, claimants 


or not. 


MR. HINNEFELD: I was just wondering. If 


they were claimants, we would have their 


record, and we could see subsequent samples to 


these. But with this level of excretion on a 


particular day, if you were to take a follow-


up sample within a couple days, you would 


expect an elevated excretion rate on that day 


as well. So, I mean, there would be a way to 


evaluate whether this was an excretion, if any 


of these people were claimants they would be 


evaluated, whether this was an excretion rate 


or a laboratory contamination event. 


If I’m not mistaken, these samples 


date from the time when the bioassay was done 


in the analytical laboratory, the same 


laboratory building where the process samples 


were analyzed for the various things analyzed 


those for. I don’t think the Health and 


Safety building was built until the late ‘50s. 


And so that’s when the bioassay analysis then 


moved from the analytical lab to the Health 


and Safety building which ostensibly was a 


cleaner environment to do those samples. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

138 

DR. MAKHIJANI: Three of these four people 


were women who didn’t have any external 


dosimetry --


MR. HINNEFELD: Right. 


DR. MAKHIJANI: -- in that period, and 


that’s really when I read Hans’ report, that 


is the thing that leaked out of me and that 


caused me to have a lot of doubt about the 


questions regarding who was being monitored, 


what their exposures were, and to stress the 


idea that the problem of fugitive emissions at 


Fernald for worker exposure could be much 


bigger --


MR. HINNEFELD: If I’m not mistaken, women 


weren’t even allowed in the production area at 


that time. So they would have had to have 


received this exposure on the, in the 


analytical laboratory or the administration 


building or the services building. 


MR. CHEW: This is dated May 13th, 1955. 


MR. HINNEFELD: Yeah, and I don’t remember 


what date exactly they let women actually go 


into the production area. I actually know the 


name of the first woman who did, Marge Kane*. 


 DR. WADE: Here’s an observation. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

139 

MS. BALDRIDGE: I think what was disturbing 


to this memo when I saw it was that Fernald 


personnel relied on their ability to predict 


which groups of people were at risk for 


exposure, and they missed it on these four and 


how many others. How many others were like 


these four people but because management 


thought they weren’t at risk, they were never 


tested or checked. 


MR. RICH: They were monitored annually. 


And if you get a major problem, you’re going 


to see routine non-monitored people show up 


with high urine. The way I would read this is 


that this is unusual. This is an 


investigation of an unusual event and a 


reporting of an investigation. 


MR. SCHOFIELD: The trouble is if these 


people give an in vivo sample annually at what 


point did they receive this dose? Was it 


three months, six months? So then we go and 


do their calculation dose reconstruction it’s 


like where are you going to set that timeline 


for their dosage construction? 


DR. ZIEMER: Well, we set it at the maximum 


point. You assume it was a year ago. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

140 

MR. SCHOFIELD: Okay, so --


DR. ZIEMER: That’s the default assumption. 


 MR. SHARFI: You have to be careful because 


with a positive result this big, you’re 


probably going to have some kind of follow up. 


So you can model what potentially was the 


intake date by back extrapolating looking at 


the follow-up samples and the positive and 


trying to fit bioassay data. If this was the 


only value that they had in their record, 


obviously you’d be looking at a much more 


claimant favorable, I mean, much more 


assumptions you’re going to have to take on 


when the intake date occurred. 


But generally, if you’re seeing 


someone at the 0.5, and obviously this report 


came out less than a month after they got the 


sample, the obviously had the ability to turn 


around and ask for follow ups. So without 


having the names and actually looking at the 


records, I can’t say there were follow ups, 


but I’d be highly surprised to see someone 


who’s so much larger than what they consider a 


significant exposure or significant bioassay 


result and not see a follow up. And once you 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

141 

have the follow ups, you can use that to back 


extrapolate what the potential intake date, at 


least the range would have been that would fit 


those bioassay results. 


MR. RICH: But like Paul says, you’d 


extrapolate. 


 MR. SHARFI: Yes, these would be sizeable 


doses depending obviously the organ of 


interest that we’re talking about. 


DR. MAKHIJANI: For purposes of information, 


do you actually, if this were the only sample 


would you in practice systematically choose 


the intake data the day after the sample? Is 


that what you do in compensable cases? 


MR. HINNEFELD: You mean the day after the 


previous sample? We go all the way back to 


the previous sample or we go mid-way. 


 MR. SHARFI: Default is the mid-point 


depending on obviously scenarios. I mean, you 


could use possibly a chronic, in a scenario 


like this it might be you’d have to, I mean, I 


hate to make generalizations about what I 


would always do because if this was my only 


point I hopefully would have more information 


I may be able to request more information or 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 -- 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 -- 

21 

22 

23 

24 

25 

142 

try to find more information. And there’s 


also information that possibly might be in 


CATI or something like that. So I hate to, 


the telephone interview. 


MR. RICH: I’ll just tell you in the case of 


plutonium facilities when we got a significant 


and detectable activity in the urine on an 


annual sample, we extrapolated back to the 


beginning period, the year. And it comes out 


DR. MAKHIJANI: In compensable cases. 


MR. RICH: Yeah, -- and it comes out a very 


high dose. 


 MR. SHARFI: The dose size would be organ 


dependent. 


MR. RICH: What I’m saying, Arjun, is not in 


the compensable program, but in the period of 


the operational program when we were 


determining doses by which to restrict people 


DR. MAKHIJANI: Oh, yeah, no, I’m asking a 


different question. I’m asking just for 


purposes because this has been kind of a 


different confusion, and so I just want. I 


want my own confusion to be cleared up. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

143

 MR. SHARFI: The default if you assume an 


acute intake would be the mid-point. 


DR. MAKHIJANI: Because this came up at 


Rocky Flats, and it’s coming up again. And 


I’ve twice put on the record that it is the 


day after the previous sample and I don’t 


believe that that’s correct. 


MR. GRIFFON: Certainly not the standard 


case obviously. 


DR. BEHLING: And even at the mid-point, and 


we’ll hear probably from Kathy, my wife, when 


she discusses some of the aforesaid cases 


where they used the day before consistently in 


five consecutive samples that were done. They 


took the day before of the bioassay as the day 


of intake. And I raised, that is an issue. I 


said why don’t you at least use the mid-point, 


and they came back and says, no, because it 


would be inconsistent if you took the midpoint because a subsequent data point would 


not fit the observed information. So again, 


it was again, well, we use the mid-point, but 


if it doesn’t fit --


MR. GRIFFON: That’s where they need more 


data. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

144

 MR. SHARFI: The difference of a single 


point assessment versus having a sizeable 


amount of data that you can actually, like I 


said, do the fits, and you can pick the 


curves. And at that point you want a midpoint that would fit this high point and then 


show that every subsequent result should have 


been in this, too. 


DR. BEHLING: So it’s a floating value or 


approach --


MR. HINNEFELD: The intake data is floating 


depending on the strength of bioassay record. 


That is true. 


DR. ZIEMER: Well, what do we do with this 


issue? It’s raised the question of these four 

cases. Can you run more from these four 

cases? Was this truly a follow-up issue or 

what? 

MR. GRIFFON: I would suggest another action 


item, that we follow up on to get the 


identifiers from that memo. See if any are 


claimants. 


DR. ZIEMER: What’s the situation for this? 


MR. GRIFFON: If you have the claimant file, 


do what Stu suggested which was to follow up 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

145 

and see if there was subsequent sampling. 


DR. BEHLING: But as a minimum and for all 


you heard this morning that a coworker model 


will be developed. Based on my opening 


statement up front was that this issue was 


raised by me because the statement I read is 


that there’s no coworker analysis has been 


deemed necessary for uranium intakes. What 


this tells us is that people who were perhaps 


not monitored should be given some assignment 


and perhaps a coworker model is appropriate 


for those for whom there is no data. 


DR. ZIEMER: Depending on what you learn 


from --

MR. GRIFFON: The second action item I have. 

DR. BEHLING: In a way you’ve answered the 

issue. 

MR. GRIFFON: The second action was that 

NIOSH will provide coworker model along with 


all analytical files on the O drive. I guess 


I should say as soon as possible because I 


think you’re still finishing that, right? 


MR. ROLFES: I’m sorry, the coworker --


MR. GRIFFON: Yeah, the coworker models. 


MR. ROLFES: Yes, that’s in process. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

146 

MR. GRIFFON: And when do you expect to have 


that in final form? 


MR. ROLFES: I couldn’t give you a certain 

date. 

MR. MORRIS: It’s hard to predict that. 

MR. GRIFFON: I know, but we’re also up 


against petitioners, too. 


MR. CHEW: It’s high on the priority for the 


RU team to do that. 


 MR. CLAWSON: I have another question, and 


forgive me for my ignorance and so forth. You 


have a pretty good idea of what to be able to 


do with these situations, but what do the 


other dose reconstructors, do we have a 


workbook? Do we have a process that when 


these abnormal ones come up, do we have a 


process or procedure to address this? I know 


some of the other ones we’ve got a workbook or 


something like that we can go to. 


 MR. SHARFI: We do try to take like we had 


guidelines that we used to try to just kind of 


help bulletize, make sure that there are 


obvious points that you want to make sure that 


you, you know, kind of summarize the site 


profile. But obviously, the site profile is 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

147 

the leading document. And then we do have, 


obviously, a support staff. We have a 


principal internal dosimetrist that you can 


bring in on any case that is probably a higher 


level expertise when it comes to either 


whether it internal or external issues. And a 


very large work staff, we have site leads that 


will help answer questions. Dose 


reconstructors are not only just given a case 


and said you’re off on your own and good luck. 


We have a whole support staff that built in --


 MR. CLAWSON: I was wondering if there was 


anything of documentation of how when we get 


this situation how do we know we handle it. 


 MR. SHARFI: There are internal dosimetry 


procedures. 


MR. GRIFFON: Well, (inaudible) be our 


guide. They sort of step it through. 


 MR. SHARFI: An in general assessments, how 


you do internal dosimetry. I mean, there are 


procedures that just cover general internal 


dosimetry. There are separate, it has nothing 


to do with the site profile. All it has to do 


with how you do, how you use bioassay or how 


you look at dosimetry or external and those 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

148 

IGs and stuff like that. 


MR. GRIFFON: As we just discussed earlier, 


I mean, the DR guidelines first step for this 


would have been external, environmental 


monitoring, and now you’re using a coworker 


model. So that’s changed already. 


 MR. SHARFI: And probably the reason why 


there hasn’t been a big push to develop a 


coworker, just like in the sense of Rocky was, 


really at the time we almost had no claims 


that required it. Almost every claim that we 


had at the time has had bioassay data. 


Therefore, when you’re looking at 


resource priorities there’s no claims that are 


awaiting a coworker, not to say that there 


aren’t possible future claimants that are 


unmonitored. But of the claims that we have 


to do at this time, they all had bioassay 


data. So the emphasis on developing a 


coworker was not as prioritized as other sites 


that have a larger need for coworker. 


 MR. CLAWSON: Okay. 


DR. BEHLING: I think the next one we can 


skip because it really addresses an issue that 


we’ve talked at length this morning about, and 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

149 

that is what are the assumptions regarding 


uranium enrichment. And just here I quote one 


of the comments in Section 5.2.1.1 of the TBD, 


and there is even a reference to, and I’ll 


quote, “During the following production year 


after 1964, the uranium was processed in a 


variety of enrichments ranging from depleted 


to as high as 20 percent.” 


Now, I’m not sure I know where 20 


percent comes from, but that’s certainly a 


high value. And but we discussed it this 


morning but it’s to the credibility of using a 


single value, two percent enrichment, for a 


select worker population who may have been 


exposed to much higher enrichment quantities. 


MR. MORRIS: Twenty percent is the value 


where it would have become a safeguard 


facility. 


MR. RICH: So they never say 20 percent. 


It’s 19.9. 


DR. BEHLING: And this was in your TBD here 


so I’m just quoting. 


 MR. CLAWSON: Okay, so I think we’ve worked 


that one pretty good, so let’s go on to the -– 


RADIONUCLIDE CONTAMINANTS IN RU, INADEQUATELY CONSIDERED
 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

150 

DR. BEHLING: I’m going to pass the next one 


on to Arjun because this one involves 


radionuclide contaminants in RU that are not 


adequately considered. And I think Arjun can 


address that. 


DR. MAKHIJANI: Well, we kind of reviewed 


this at some length in the TBD. You put up a 


slide there this morning of where you said the 


average plutonium contamination of recycled 


uranium was 0.9, and you had some other 


numbers. And the 2003 DOE report, which 


revised the 2000 report, even though it was 


partial had higher numbers for the average. 


Let me see if I can pull up some of the 


numbers. 


So anyway the first point is that I 


think there’s documentation to indicate that 


the values that NIOSH are using are not based 


on complete information. And there’s 


information showing that average values are 


higher and maximum values were higher. The 


maximum value cited undiluted, unmixed for the 


Paducah tower ash in the TBD is 412 ppb. I 


think that’s also indicated not to be the 


highest value. I cited a value of 1,000 ppb. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

151 

And there are other values also. 


I am not at all sure that any DOE 


investigation to date is seriously complete 


and has the necessary information about the 


levels of contamination of RU with plutonium; 


and therefore, all the other contaminating 


materials. But certainly I think there’s 


documentation to show that the existing TBD is 


not correct. I mean, maybe I’ll just make 


that first point. 


There are a lot of points in regard to 


raffinate. I don’t think the NIOSH response 


in the matrix is responsive at all to the 


raffinate because raffinates don’t involve 


radon breath. They don’t involve Radium-226 


and isotopic analysis of the silo contents. 


So the response that NIOSH has given about K65 raffinate drums, what’s in the silos does 


not contain significant data on the RU streams 


and the plutonium and neptunium contamination. 


And so far as I’m aware, I have not 


found any information on the plutonium 


contamination in the raffinate stream. But I 


think it is important. There’s something that 


Stu wrote in 1988. 

1 

2 

3 

4 -- 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

152 

MR. HINNEFELD: That’s really dirty pool is 


quoting something I wrote. 


DR. MAKHIJANI: Let me find it, and actually 


 MR. CLAWSON: Maybe Stu could quote it for 


us. 


MR. HINNEFELD: I know what the issue is. 


The issue is in the refinery when -- the 


little bit it operated when I was there -- the 


feed in the refinery were not high in radium. 


So it’s not a radium issue. There was some 


Thorium-230, a little bit, it’s all been, this 


stuff’s all been purified once before. So 


it’s only about Thorium-230 going back in. 


There’s not even very much of that. 


But the recycled uranium in the feed 


may have gone in at ten parts per billion or 


something or some of it was as high as maybe 


30 parts per billion on occasion, would go 


into the feed, and the refining process would 


purify the uranium and take impurities out, 


impurities including these radiological 


contaminants. 


So on the raffinate stream which is 


the discharge stream from the refinery, you 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

153 

have very, very small amounts of uranium. I 


mean a little bit did leak through, but most 


of the uranium went to the product stream. 


But the impurities preferentially went to the 


raffinate stream. And so the proportions that 


were used for feed materials and product 


materials in order to bracket those numbers 


can’t really be applied to raffinate numbers 


because the uranium’s all gone. 


And since you’re basing on a ratio of 


say plutonium to uranium, uranium’s, that 


ratio goes way up. And as I recall, we 


approached control on the raffinate on 


essentially a mass basis. You know, it was 


not very radioactive at all because uranium’s 


pretty much gone. You’ve got a little bit of 


contaminants. It’s not very radioactive at 


all, but the components were there was not 


uranium, and you couldn’t really scale on 


uranium. 


So I think the issue might be if 


bioassay here is depending upon uranium 


bioassay, that person’s exposure environment 


is raffinate, you know, he was exposed to 


raffinate, then uranium bioassay and the kinds 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

154 

of ratios that you’re using for plutonium to 


uranium that are based on feeds and products, 


those ratios aren’t applicable to uranium 


bioassay in a raffinate exposure environment. 


DR. MAKHIJANI: I could not have said it 


better. So this is exactly --


MR. HINNEFELD: That scares me so much. 


DR. MAKHIJANI: -- that’s exactly the point. 


 MR. CLAWSON: Ray, you’ve got that written 


down. They agreed. 


DR. MAKHIJANI: And you said this back then. 


MR. HINNEFELD: Yeah, I read what I said 


back then, and I couldn’t think of a reason to 


say something different today. 


DR. MAKHIJANI: And the whole NIOSH analysis 


is based on the ratio. And so far as I know, 


I mean, Stu, are there any measurements --


MR. HINNEFELD: Well, I haven’t participated 


in this product because I’m conflicted at 


Fernald. 

DR. MAKHIJANI: But just from your 

knowledge. 

MR. HINNEFELD: There are some measurements 

of raffinate materials that were collected in 


circa ’85 give or take a little bit timeframe. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

155 

And there are some evaluations of those ratios 


in raffinate materials. I don’t know how 


extensive they were, but they were out there, 


taken during that ’85 period. 


DR. MAKHIJANI: And how would you, so the 


question is recycled uranium comes to the site 


around 1960. You’ve got 25, 29 years of 


processing, however many years there were, and 


you have one data point for raffinates in the 


mid-‘80s. Now, I haven’t seen that data, but 


this is exactly the issue that we had at 


Mallinckrodt when NIOSH said, okay, actually 


uranium bioassay data are not suitable for 


this kind of situation, raffinates, and went 


to radon breath data. 


But there we didn’t have the 


complication of trace contaminants with 


transuranics. There we were only talking 


about everything that’s in natural uranium, 


and so we had a different situation. Here you 


have a more complicated problem I think where 


characterizing these raffinates is going to be 


much more difficult. And if uranium bioassay 


is not suitable, the question is what’s the 


data that’s going to be used in order to 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

156 

reconstruct these doses. 


So there’s two problems. One is the 


RU data itself and the feed material 


characterization, which I think is inadequate, 


at least so far as we reviewed it. And then 


the raffinate problem which I think is 


actually a more serious problem. 


MR. ROLFES: One thing to keep in mind is 


that the extraction of the raffinates was a 


wet process, and it was also enclosed in 


process piping. We have found some 


confirmatory air samples to indicate that the 


measure to air concentrations were relative 


low. I know we have reviewed multiple 


samples. The total number in years off the 


top of my head I couldn’t provide to you at 


this time. 


I believe we’re going to be addressing 


additional exposures to recycled uranium 


contaminants within our updated internal dose 


technical basis document which we’re in the 


process of revising at this time. 


MR. GRIFFON: Would you have a way to 


identify raffinate workers or workers that 


were in that? I’m assuming it was only one 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

157 

area of the plant, right? 


MR. RICH: It’s Plants 2 and 3, and Plant 3 


was the, and the raffinates were not just 


raffinates. There were hot raffinates, and 


there were cool raffinates --


DR. ZIEMER: Radiologically or thermally? 


MR. RICH: Radiologically. 


MR. HINNEFELD: Radiologically. 


MR. RICH: The hot raffinates are high in 


Radium-226. The cold raffinates are just 


other trace materials and fundamentally 


natural uranium that came and was processed 


through Fernald but had already gone through 


the mill operation where the daughters were 


removed. And so as a consequence, the cold 


raffinates had very little uranium daughters 


and essentially cold in comparison with the 


first-time pitchblende ores. 


And there’s a little twist that we’ve 


discovered also, and that is it turns out that 


the primary recycled uranium that was received 


at the plant came from Hanford, as you agree, 


did not go through the plant. It went 


directly to Plant 4 and was blended there. 


And so there wasn’t a concentrating mechanism 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

158 

for a good share of it. 


Scrap materials from the processes 


were then processed through the plant, but 


that is a reduction in the total amount of 


recycled uranium contaminants that actually 


went through the extraction plant. 


MR. MORRIS: That’s only ten percent by mass 


they said. 


MR. RICH: And as a consequence, as Stu 


indicated, the contaminant levels sampled at a 


much later time were low, but where we are 


developing with air sampling and with improved 


knowledge of material flows a default. Right 


now we’re defaulting at 100 parts per million 


for everyone in the plant based on uranium. 


MR. HINNEFELD: One hundred parts per 


billion. 


DR. BEHLING: What’s a thousand --


DR. MAKHIJANI: I guess you put all the 


raffinate issues on the table. I would like 


comment on the recycled uranium raffinates, 


but since you have discussed all of the --


MR. RICH: This Board is going to be 


considerably upgraded in upcoming technical 


basis document. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

159 

DR. MAKHIJANI: But the one comment I had 


about the cold raffinates that were from ore 


concentrates that were processed at Fernald. 


The radium was left behind at the 


concentrating plant, I agree. And those 


wastes were sent to Silo 3. If you look at 


Silo 3 data, you see that the Thorium-230 


content at Silo 3 is very high relative to 


radium. I think I have the data right here. 


MR. RICH: It becomes the controlling --


DR. MAKHIJANI: Yes, but the thorium in Silo 


3 averaged 51 nanocuries per gram and the 


radium’s only about three nanocuries per gram, 


almost 20 times bigger. And there’s a lot of 


reliance on that silo isotopic ratios, but I 


think that’s easier with the pitchblende 


because you know pitchblende is a better 


characterized material. 


I think ore concentrates came over a 


period of time, probably from different places 


and different mills and different ores. And I 


think the Thorium-230, Radium-226, uranium 


ratios would not be expected to be constant. 


So from Silo 3 characterization to 


have an average ore concentration, ore 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

160 

concentrate processing information that I 


don’t, that I think would be applied to a 


population of workers, I haven’t seen anything 


that applied it to an individual worker. 


MR. RICH: And as a general rule, Arjun, if 


you take the analytical data in the silos from 


a later time, you’re going to maximize, it 


would be claimant favorable because the long-


lived isotopes are going to increase in ratio. 


DR. MAKHIJANI: No, no, I’m only talking 


about radium and thorium where the (inaudible) 


doesn’t enter into it because it hasn’t 


changed in the time period that we’re talking 


about and --


MR. RICH: But when you compare to gross 


alpha activity, for example, then the ratio on 


the air sampling data, and we have some air 


sampling data that we’re going to be folding 


into this analysis. 


DR. MAKHIJANI: I guess I’m maybe not being 


clear. As I understand it these ratios are to 


be applied to urinalysis data. That’s the 


preferred method of dose reconstruction if you 


have a certain isotopic ratios, and to 


calculate the radium and Thorium-230 doses, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

161 

you’re going to apply uranium and then use 


these ratios to calculate the intakes of 


radium and thorium. 


MR. RICH: I’m going to do it a little bit 


differently on that because of the fact that 


the uranium, it really doesn’t. You can’t do 


a ratio for exposure in the plant areas. 


DR. MAKHIJANI: I understand for the 


pitchblende workers and the Silo 1 workers 


you’re using radon breath data. But I don’t 


think that is a, my focus in making this 


comment on the cold raffinate is that radon 


breath is not relevant to that. 


MR. RICH: Correct, it’s true. 


DR. MAKHIJANI: And so, well, let me just 


pose a question. How are you going to 


identify the workers who worked with ore 


concentrates, and how are you going to assign 


a Thorium-230 dose to them? 


MR. ROLFES: That will be based on the 


information that have within our technical 


basis document. It’s still in draft form; 


however, as Bryce as mentioned, we do have air 


monitoring data associated with those 


processes. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

162 

DR. ZIEMER: And you can identify where the 


people worked in these cases or not? 


MR. RICH: According to the managers, Plant 


2 and 3 have an up and down period of time. 


They didn’t operate full blast for the whole 


period, and so during the peak of operations 


they had about 100 people that were operating 


that plant. Can we identify the individuals? 

I doubt it. 

MR. CHEW: Sometimes. 

 MR. SHARFI: Yeah, sometimes. It kind of 


depends on what’s in the claimant files. 


MR. RICH: And what period of time. 


 MR. CLAWSON: We have a comment here. 


MR. BEATTY: Yeah, just a clarification on 


those work assignments as a former worker. 


That, yes, people back in the early years were 


assigned a building normally, and those, 


especially chemical operations, and that was 


for security reasons. However, maintenance 


was a different ballgame. They had an 


assigned building, but then on the, like 


overtime, they moved around, all around. 


MR. RICH: And that’s because of the ebb and 


flow of operations at Plants 2 and 3. And 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

163 

that changed because of the fact they were 


shut down. 


MR. BEATTY: Yeah, it seems like the metal 


side would get a peak time where they would be 


more active than the chemical side; you’re 


right. However, the time that the people put 


in those buildings, I think there should be a 


point of emphasis made in the interview 


process to emphasize how important it is to 


capture all the buildings they were in. 


DR. BEHLING: I think that’s one of the 


findings that we discussed. Hopefully, we’ll 


get there. It’s the issue of associating 


people with specific work locations. 


MR. GRIFFON: Can I ask? So I know we’re 


waiting for this and that’s an action I have 


here is an update on the site profile, but did 


I just hear you say that the cold raffinate, 


the answer is going to be based on thorium air 


sampling? Are you going to default to air 


sampling data? 


MR. RICH: It would be dose air sampling. 


MR. GRIFFON: Instead of any kind of ratio. 


MR. ROLFES: Yeah, the ratio wouldn’t apply 


in this scenario because of the low 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

164 

concentration of uranium associated with the 


silo. 


MR. RICH: It just doesn’t fly. 


MR. GRIFFON: So we’re waiting on thorium 


air sampling data. I mean, we don’t have that 


either, do we? Do we have that posted 


anywhere? 


MR. ROLFES: We’ve got quite a bit of 


thorium air sampling data, and I know I 


haven’t reviewed all of it. 


MR. GRIFFON: But, I mean, is it in a --


DR. MAKHIJANI: Two thirty? 


MR. GRIFFON: -- spreadsheet format or is it 


in a --


MR. ROLFES: Yes, yes, we do have 230. We 


do have thorium air sample data that is 


directly associated with this raffinate 


process. We also have gross alpha analyses 


for thorium. So we’ll get that posted. 


DR. MAKHIJANI: Thorium-230 is --


MR. ROLFES: Yes, there are air samples 


labeled specifically as Thorium-230 at 


Fernald. 


MR. GRIFFON: Is this in spreadsheet format 


or --

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

165 

MR. ROLFES: No, these are not transcribed 


yet I don’t believe. These came out of the 


data capture that was conducted at the federal 


records center in Dayton, I believe. 


MR. GRIFFON: I mean, I would suggest that 


these things be posted even if, you know, even 


before the site profile finished so we can 


have a chance to digest this. 


MR. ROLFES: I understand. There’s just an 


overwhelming amount of data. And some of 


these documents may not have been named 


Thorium-230 samples yet. They may still have 


like a, you know, several numbers, and I ‘d 


like to try to organize them a little bit so 


they’re presentable so that you can look 


through and find them in some reasonable 


manner, I guess, without hunting. 


MR. RICH: As I’m looking. 


MR. ROLFES: Yeah, yeah, true. 


DR. MAKHIJANI: May I make a request in that 


regard? Did the documents have some kind of 


brief on this title because a lot of Fernald 


documents references for the evaluation report 


that are posted just had numbers, and that 


makes a review extremely difficult. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

166 

MR. ROLFES: I agree. I couldn’t agree 


more. 


MR. RICH: We can agree with you on that, 


Arjun. 


 MR. CLAWSON: That’s two today. 


One other thing I’d like to make a 


point. I may not mean anything, but, Mark, 


you made a comment that the raffinates were in 


a liquid form and so that it wasn’t quite as 


much of a problem. Be sure to remember this 


is a maintenance process. We do have a lot of 


leaks in the process that dry themselves out. 


Usually where the leaks at, it’s also 


by air moving systems or whatever else like 


that. So just because it was in the dry form, 


and I look at from a maintenance standpoint 


because even when you take one of these 


systems out or so forth like that, you’ve got 


to dry the system out before you can get in 


there. So now you’re getting into a whole 


other issue that now it is dry and airborne. 


MR. RICH: And then part of the raffinates, 


Brad, also were extracted on a rotor-to-jump 


filter and knifed off, and that was dried into 


a filter cake and then airlifted. So it was a 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

167 

dry material when it was actually went out to 


the silo. 


 MR. CLAWSON: Well, the --


DR. BEHLING: The next one is also one that 


I’m going to defer to Arjun, Finding 4.1-6. 


DR. MAKHIJANI: We may have covered that. 


Yeah, I think we’ve covered that in, this is 


sort of a feed material for RU data. We could 


review. And I think I’ve given you all the 


references that I have. 


MR. GRIFFON: And I assume, in capturing the 


actions, I assume that that’s going to be 


captured in the site profile update, right? 


DR. BEHLING: Yes. 


K-65 DEFAULT MODEL
 

The next one is on page 36 of the 


report and it addresses the issue of the K-65 


default model. And my statement that you will 


see in the matrix is strictly defined as the 


K-65 default model is inappropriate. And I 


analyze that. In fact, if you look through 


the TBD it is heralded as a very claimant 


favorable model. And from what I gathered 


this morning, it is a model that will not be 


used in the future or will it be used? 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

168 

MR. ROLFES: No, this is also one of the 


changes that has taken place as well. Would 


you like to --


DR. BEHLING: I will go through as to what I 


believe were some serious flaws to it that are 


clearly not claimant favorable because it’s 


based on, to a large extent, external doses. 


Here we’re trying to assess internal 


exposures, and we’re trying to contain the 


internal exposure model by means of external 


doses that were monitored. 


And if you go through my write-up, you 


will see a series of assumptions that are 


clearly not appropriate in terms of confining 


it to a certain period of time based on 


administrative dose minutes that were imposed, 


et cetera, et cetera. And you end up with a 


six-week period which is clearly 


inappropriate. 


And I question, for instance the whole 


issue of a three shift. I know that there was 


a document that references three shifts, but 


it may very well have been people who work 


with raffinates that were being processed at 


Fernald as opposed to the 13,000 drums. I 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

169 

have a difficult time in getting to believe 


that there were people staying an extra 


conveyor belt, shoving the contents of drums 


onto a conveyor belt that’s being lifted up 


into the silos in the middle of the night. 


I mean, it makes no sense. And so 


this whole model as far as I’m concerned is 


based on assumptions that I cannot agree with. 


They’re broad assumptions, and assumptions 


that are counter-intuitive. 


MR. RICH: A number of things. You’re 


right. It turns out that some of the drums 


were slurried, taken to a location, slurried 


and transferred out the dumping-off place and 


was carefully monitored. It was monitored for 


gross alpha. And then, of course, that was 


the basis for the original default in the 


original technical basis document. We’re 


modifying that now, but that data is still 


available in terms of actually bounding, 


making sure that it’s bounding. So they’re 


sampling radon breath analysis. 


MR. ROLFES: Yes, NIOSH feels that this may 


have been an SEC issue, but because the 


additional data that we have located, this has 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

170 

allowed us to basically supplement our 


approach for dose reconstruction. And we feel 


that it’s no longer an SEC issue based on the 


additional data that we do have because of the 


radon breath analyses, the air sample results 


and updated information. 


DR. BEHLING: So you’re not going to use 


this model I take it. Because like I said, I 


find faults right down the line, and I 


identified each of the elements --


MR. CHEW: We’re not going to use the model 


that was in the environmental. 


MR. RICH: Hans was saying that he had a 


problem with the breath analysis --


DR. BEHLING: No, no, I have problems with 


the assumption that, for instance, the period 


of time was restricted to ten weeks, then to 


six weeks, and it was all based on external 


doses involving 13 of the 22, and ultimately 


there were dose restrictions or administrative 


dose that don’t fly with the data that I have 


that says during that time it was 300 millirem 


per week, and 15 millirem per year, et cetera, 


et cetera. And so all these assumptions that 


are artificially introduced here to reduce the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

171 

time period for exposure had no scientific 


basis. 


MR. RICH: Probably a waste of time to 


justify the original technical base document 


that we’re not going use that precisely. We 


may use some similar analyses but not those, 


so we’d probably just drop that. 


DR. BEHLING: Okay. If the new model is a 


facsimile of the old, I would certainly want 


to look at it again because there were just 


flaws after flaws after flaws introduced. 


MR. RICH: Well, it appeared at the time 


that it was going to be a conservative 


default. 


DR. BEHLING: Well, it is in my estimation 


anything but conservative. 


 MR. CLAWSON: You know, one of the comments 


that was made here was the closely monitored 


and so forth like that. Have we extracted any 


of the DOE reports on Fernald? I’m talking 


like Tiger Teams and reports. The reason I 


bring this up is when we were here in 


Cincinnati and just starting into Fernald, I 


know that several of the former workers and so 


forth questioned that I know that Fernald was 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

172 

beat up very, very severely for a very poor 


Health Physics program or RAD program or 


whatever like that. A lot of stuff came into 


this. 


I’m thinking even in the mid-‘80s 


there were some reports that were put out of 


this. So are we gathering any of this? 


Because one of the petitioners -- well, not 


petitioners, but one of the former workers 


made the comments of DOE coming in and totally 


having to reconstruct or re-put together their 


RAD monitoring program because of fallacies in 


it. 


And I guess the point that I’m trying 


to get to is we’re basing everything off of 


this. We’re basing that all this information 


is in there, and if it’s flawed data, you 


know, this is all like a big computer. If you 


put good stuff in, you get good stuff out. 


You put garbage, you get garbage back out. 


And I just wanted to see are we addressing any 


of the reconfigurations of their air sampling 


programs for flaws. Are we looking at any of 


these DOE reports, the Tiger Teams, the so 


forth like this? Because I know they got ate 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

173 

up pretty bad. 


MR. ROLFES: Sure. For example, like the 


bioassay data, the urine samples were 


evaluated using a document and accepted 


practice. Air samples as well were taken 


based on a document, documented in procedural 


practice. 


These weren’t things that were new to 


Fernald but had been around since the ‘40s. 


Many of the procedures for evaluating worker 


exposures had not just been invented at 


Fernald. They had been carried on from a 


previous experience, for example, at Oak 


Ridge. And there may have been some 


shortcomings and a control of contamination 


and things, but the records that we have 


received, we had no indication that the 


records are suspect or falsified if that’s 


where you’re --


 MR. CLAWSON: No, I’m not --


MR. HINNEFELD: But your question hints to 


there were Tiger Team reports which are, I 


think, goes late ‘80s. There was a report 


written essentially at the end of the NLO 


year, which would have been ’84, ’85 that took 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

174 

to task pretty significantly the radiation 


protection program, and how we pulled out 


those reports and said of these findings that 


were identified in these reports, do these 


relate to this data that we intend to use. I 


mean, do they impeach the bioassay data. Do 


they impeach the dosimetry data? So that’s 


the question is can we go get those reports 


and make that evaluation. 


 MR. CLAWSON: And the reason I bring this up 


is because I know it’s stated in public 


comments many times about this. And I want to 


make sure that the former workers and so forth 


that we are addressing these issues, and would 


pull up, and I’m just roughing off what was 


said, but it was clearly portrayed to me that 


they had a new way of mossing, let’s put it 


that way, because of a flawed process. And I 


just want to make sure that we’re looking at 


that. 


MR. GRIFFON: Stu, what were those report 


references again? 


MR. HINNEFELD: Well, the Tiger Teams were 


the late ‘80s. 


MR. GRIFFON: The Tiger Team, and then what 

1 

2 

3 -- 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

175 

was the other one? 


DR. ZIEMER: Well, it was in the early ‘90s 


MR. HINNEFELD: I’m going to say -- was it 


early ‘90s? Okay, early ‘90s for the Tiger 


Team. 


I’m going to say there was a report 


called the Gilbert report. Gilbert was the 


author, and that was written -- have we seen 


that? 


MR. ROLFES: Off the top of my head I don’t 


recall seeing it. 


MR. HINNEFELD: If I’m not mistaken, the 


Gilbert report was written, would have been 


probably been ’84 or ’85 that sort of assessed 


NLO’s operation of the Fernald site. And I 


believe it was pretty critical. I remember it 


being pretty tightly held when it came out. I 


mean, they didn’t just show it to everybody. 


And so that contained a lot of these comments. 


I mean, the early-on comments I think 


it led largely to contractor change. You 


know, DOE’s recognition of how Fernald or how 


NLO was operating at Fernald’s plant, 


particularly, you know, probably health and 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

176 

safety, but probably other things as well, led 


to re-bid of the contract. Up until then 


they’d always just re-awarded it to NLO. It 


led to a re-bid of the contract and change of 


the contract. 


So that’s the kind of report that’s 


being asked about here. And so I think it’s 


our responsibility to make sure we’ve looked 


at those documents and see do any of these 


findings affect how we consider this data that 


we’re relying on. 


 DR. WADE: Does it impeach any of the data 


that we’re building --


 MR. CLAWSON: And you’ve got to understand 


from our standpoint, as a Board member I’m 


tasked to assure that the data integrity is 


good, and this is why I’m bringing this up. 


 DR. WADE: So it would be wise to get that 


report posted and then offer an opinion as to 


whether the data foundation is impeached by 


it, but let the Board members and others offer 


their own opinion. 


 MR. CLAWSON: Well, and also, if that can be 


put on the web because I know it has come up 


several times at the site. I want the workers 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

177 

to realize that we are looking at this, that 


just because they’ve made these comments that 


we are trying to address them. 


MR. ROLFES: NIOSH takes, you know, we are, 


I believe, very responsive to workers. When 


workers -- I know I started off doing 


telephone interviews with several workers, and 


if they had something on their mind, they’d 


tell you. We didn’t just ignore these issues. 


We do consider these issues. 


These are public documents and 


workers’ input is important to NIOSH so we do 


take these issues seriously. And we want to 


make sure -- we’re getting into great details 


with each, with these discussions, and we want 


to make sure that we are adequately addressing 


any corporate concerns or issues. And I want 


any workers that are on the line also to make 


sure that if they have questions about what 


we’re discussing, we will be happy to spend as 


much time as we need to discuss these issues 


with them. 


 MR. CLAWSON: And I understand that, Mark, 


and I’ve never in any way questioned NIOSH’s 


or anything else integrity. This is just one 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

178 

of the things that kept coming up to me in 


reading this report here and stuff like that. 


It really didn’t address anything like that, 


and I wanted to assure that we’re looking at 


that because there was a change in the 


process. There was a changing of the guard, 


and there was a changing of the guard for a 


reason. 


DR. MAKHIJANI: There’s also volume 4 of the 


Westinghouse Transition Report --


MR. HINNEFELD: Yeah, there is the 


Westinghouse Transition Report. 


DR. MAKHIJANI: -- that covers this. I 


referred to it, but it should be accessible to 


you. 


MR. HINNEFELD: It should be. 


DR. MAKHIJANI: I have a copy of it if you 


don’t have that. 


DR. BEHLING: I think the next finding again 


is something that Arjun will address, Finding 


4.2-2. 


DR. MAKHIJANI: I think we’ve covered this. 


I mentioned that the cold raffinate question 


was a separate item. This is the cold 


raffinate item basically. The Thorium-230, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

179 

basically, the radon breath analysis is now 


going to be, leaving aside the question of 


adequacy of radon breath analysis for where 


you have radium, it’s now going to do the job 


for the cold raffinates. And so I think we’ve 


already discussed that, and you’re going to 


present a different method for that. 


RAC 1995 REPORT
 

DR. BEHLING: That brings us to Finding 4.2­

3 on page 47. And I think again this may be 


an issue that you can resolve fairly quickly, 


but my concern, or my finding, really 


addresses the RAC 1995 report and the model 


that came from it. In that report it was 


stated that about five -- and I quote it here 


in the report. It says, “During the 1953 to 


1978 period, five to six thousand curies per 


year of Radon-222 were released from the 


silos,” and so forth. 


And I looked at that, and that 


translates to 15-to-20 curies per day. And I 


looked at the actual radionuclide mixture that 


were categorized for Silos 1 and 2, and 


specifically I looked at the Radium-226, the 


Polonium-210 and the Lead-210, and looked at 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

180 

the ratios. And I realized the degree of disequilibrium, and then I also looked at the 


total quantity. And then on the basis of mass 


balance, I calculated probably a release of 


closer to 90,000 curies per year. 


And that’s strictly based on the fact 


that Lead-210 would be there if radon didn’t 


escape the silos. And I believe the 


difference is that there was no dome cap for a 


long period of time until the ‘80s that would 


have retarded the escape of radon. And so 


based on first principles and simple mass 


balance, I calculated a value that’s ten to 18 


times higher than that assumed by the RAC 


Report. And I just throw that out as an issue 


that you may want to look at. 


MR. ROLFES: This is another issue that we 


don’t believe is an SEC issue at this time. 


We’re also revising the environmental internal 


dose or the environmental section of the 


technical basis document. And we’ve also 


adopted a new methodology that will be 


detailed in this technical basis document 


revision. 


And this is part of the Pinney Report 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

181 

that was conducted, and let’s see. I guess, 


I’ve spoken with Susan Pinney once or twice 


regarding this model, and it basically is 


employing very claimant-favorable assumptions 


regarding potential worker exposures. And I 


believe she basically has modeled worse-case 


scenarios essentially for workers where there 


was uncertainty where the worker was, in fact, 


working at the plant. Now, her model 


incorporates radon emissions from the K-65 


silos as well as from some of the other areas 


such as the bins, I believe, that was the Q-11 


source term, the bins that were outside of 


Plant 2, 3 if I recall. 


MR. BEATTY: Ore silos, too, Mark? 


MR. HINNEFELD: They call them the ore 


silos. They were up on the side of Plant 1. 


MR. BEATTY: South of Plant 1. 


DR. MAKHIJANI: Do you have the interviews 


with Dr Pinney documented? 


MR. ROLFES: They were short interviews. 


The documents which she provided to us have 


thousands of data points, and we can 


definitely make that available to the Advisory 


Board as well. So I would have to take a 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

182 

look. I spoke maybe ten minutes with her on 


the telephone several months back, and I 


didn’t --


DR. MAKHIJANI: No, no, it’s not, this isn’t 


some kind of pro forma thing. It’s just if 


there’s, if the information she gave you is 


contained in a document so the (inaudible) 


that she did. 


MR. ROLFES: Yes, yeah, we do have several 


reports, and we have a slideshow that she has 


prepared. There’s quite a bit of information 


that she has provided to us. 


DR. ZIEMER: The bottom line is that you’re 


not using this model any longer. 


MR. ROLFES: Correct. 


DR. ZIEMER: And there’ll be a new TBD out 


that will cover it. 


DR. MAURO (by Telephone): Mark, this is 


John Mauro, just a real quick question. The 


model as I recall that was used in RAC 


basically measured the radon concentrations in 


the head space of the silos, and then it had a 


way of predicting diurnally due to pressure 


changes from day to night, venting through 


cracks in the silo as means of coming up with 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

183 

that 5,000 curie number. So that method is no 


longer being used. Is that correct? 


MR. ROLFES: I believe the differences in 


emissions is accounted for based on the shift 


that the worker was onsite. I believe those 


considerations were evaluated in Dr. Pinney’s 


model. That methodology -- excuse me, the 


original ORAU Technical Basis Document 


methodology though, based on the RAC Report, 


is not going to be used at this time. 


DR. MAURO (by Telephone): Okay. 


 MR. CLAWSON: Ray, did you have something 


you wanted to --


MR. BEATTY: Yeah, I’d like to make a 


comment first of all. The mention Hans makes 


of the levels of radon emissions coming from 


K-65, yeah, they did diminish greatly when the 


bentonite* clay was applied and the berm was 


put around the silos from the cracking. In 


the later years there was even other processes 


done, as in the remediation years for foam, a 


foam spray was applied and the manholes were 


double-sealed and various things. 


My point is that there was still a 


large amount of emissions coming off the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

184 

silos, and as late as ’96, and I have this 


documented on calendar, that we were warned to 


stay indoors on a certain day due to high 


levels of radon. 


MR. ROLFES: Yes, during certain atmospheric 


conditions when there was an adiabatic 


inversion, that’s what it was called. 


Basically, when the clouds dropped down really 


low, and basically you can see a ceiling, a 


very low ceiling of clouds. The radon that 


was being released out of the silos would, in 


fact, be trapped down below that cloud layer. 


And so there were some times when the radon 


concentrations did not dilute as rapidly as 


normal. And so, yeah, that is a good point, 


so I’m sure you’re right. 


MR. BEATTY: If I may, just as some help to 


the Board or working group especially, I have 


a copy of this Pinney’s Report and the Q-11, 


K-65 studies as well as a letter personally 


from Dr. Pinney as to the findings. If they’d 


find that beneficial, I’d sure be able to 


supply that to you. 


DR. MAKHIJANI: If you have a copy here, 


maybe you could just get it done at the hotel 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

185 

during the lunch break. 


DR. ZIEMER: Is this what you were referring 


to already or is this something that --


MR. GRIFFON: It might be similar or it 


might overlap, but --


MR. BEATTY: It’s the actual presentation by 


Dr. Pinney. It’s the one that showed the 


peaks of the two and three area. It showed 


like a CAD description, time to its higher, 


yeah, I’m talking about the smoking and radon. 


MR. ROLFES: It’s probably the same thing or 


very similar to what --


 MR. CLAWSON: Why don’t we at least take a 


look at that? 


Due to the time right now --


MR. GRIFFON: I just have something before 


if you’re going to break for lunch or 


something. I’m trying to track these action, 


and I noticed that on Finding 4.2.1 in the 


matrix you have ORAUT-TBKS-0017-5 revision in 


draft? 


MR. ROLFES: Uh-huh. 


MR. GRIFFON: And then the one we just 


looked at is -4? 


MR. CHEW: Environmental. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

186 

MR. GRIFFON: Environmental, that’s the 


environmental section, okay. So they’re both 


updating drafts of the -- all right, I wanted 


to make sure I had the numbering right. That 


was it. 


DR. MAKHIJANI: Are you going to read the 


action items now or later? 


MR. GRIFFON: I’ll read them all later. I 


mean, I only read those first ones from the 


first finding, so we’ve had several more. 


MR. CHEW: Within our team we’re having a 


constant battle within ourselves because the 


environmental TBD was to try to address 


ambient environmental exposure. This is 


really a worker that’s working outside. And 


so does it really fall into the internal side 


or is it more fall under the environmental 


side? We have lots of data in the 


environmental report, and so I think I’m 


trying to make a decision right now how to 


word --


MR. GRIFFON: I guess that’s why I was 


confused because I thought it was, could have 


been the same one. 


MR. MORRIS: Is the environmental section 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

187 

going to be this big or this big? 


MR. CHEW: And also a person working outside 


next to a silo --


MR. GRIFFON: I thought at first it was a 


typo, maybe that’s why. 


 MR. CLAWSON: After they had the fire with 


the release out of the stack, whatever you 


want to put it to, wasn’t there an outside 


group with Fresh or so forth like that, that 


did actual monitoring outside of the Fernald 


site? Mark, wasn’t there an independent group 


that pulled air sample data? 


MR. ROLFES: There may have been. I know 


that Fernald employees didn’t travel offsite 


to take measurements. Back in the early days 


we have documented air samples from distant 


locations --


MR. HINNEFELD: I think the State Board of 


Health. 


DR. ZIEMER: The State Board of Health. 


MR. HINNEFELD: I think the State Board of 


Health does the sampling. ASTDR, the agency 


for --


MR. ELLIOTT: ATSDR. 


MR. HINNEFELD: ATSDR, Agency for Toxic 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

188 

Substances and Disease Registry. 


DR. ZIEMER: Didn’t they get involved 


somehow --


MR. HINNEFELD: They had a citizens’ 


advisory group. That was related mainly to 


exposures to the neighbors. ATSDR was mainly 


(inaudible) by exposures to the neighbors to 


evaluate those, and the (inaudible) came out 


of that. 


 MR. CLAWSON: Well, I just wondered. It 


might be a problem. 


MR. HINNEFELD: Yeah, I don’t think they 


took any samples. I don’t think the ATSDR 


took any samples. 


MR. ELLIOTT: They did not, and it was NCEH 


that had an advisory subcommittee out there. 


And NCEH looking at pathways out there. 


 MR. CLAWSON: I was just wondering. I know 


that it was addressed at one of the meetings 


that we looked in the comparing it to what the 


actual site profile was. I was just throwing 


that out for an informational thing of if we 


have compared this to anything that was --


MR. MORRIS: Well, at some level it’s 


probably not productive. You know, the fence 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

189 

line access is pretty far away from the 


operational cases. And turbulence and 


assumptions about air sample location all make 


that a hard to compare dataset. Maybe you 


could have found it in some comparable data 


for a very high emission action that both were 


monitoring at the same time, but those are 


going to be rare to actually find comparable 


data I think. 


MR. HINNEFELD: Yeah, you should ask John 


Burn, works for the ORAU team. Ask John Burn 


if he knows about whether the State Board of 


Health did that sampling, and, if so, where 


would that data be. 


 MR. CLAWSON: Okay. 


 DR. WADE: Ready for lunch? 


 MR. CLAWSON: We’re ready for lunch. 


 DR. WADE: You want to go ‘til one? 


 MR. CLAWSON: Yes, if you would, please. 


 DR. WADE: For those of you on the phone 


we’re going to break for lunch. We’re going 


to break the phone contact. We’ll call back 


in about five minutes before one. Thank you. 


(Whereupon, the working group meeting took a 


lunch break at 12:02 p.m. and returned at 1:05 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

190 

p.m.) 


 DR. WADE: We’re about to go back in 


session. John Mauro, are you with us? 


DR. MAURO (by Telephone): Yes, I am. 


 DR. WADE: Good, okay. 


Brad? 


 MR. CLAWSON: Hans, if I remember right, we 


were stopped at 4.2-2? 


INTERNAL DOSE ESTIMATES FOR THORIUM
 

DR. BEHLING: Yeah, we were up to page 49 of 


the report which starts with findings 


associated with internal dose estimates for 


thorium, and in those couple pages I provide 


some background information and introduce the 


assumption about the model that had been 


identified in the original TBD. 


I’m not sure it’s still, it’s a model 


that is expected to be used. But the model 


involves a hypothetical intake of 1,050 MAC 


hours that was derived -- and I won’t go into 


the details. You can quickly scan through. 


It’s on page 50, the report, what that 


particular model was based on. 


And if you go to page 52, the report 


is really the first finding. And I wanted to 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

191 

just kind of look at the basic limitations 


that you experience when you rely on air 


monitoring data. And I brought up in that 


particular finding a study that was done at 


NUMEC that was, that compared the lapel air 


sample to general air sample data, and just to 


show that there are severe limitations 


associated with air sampling data, 


specifically general air samples. 


And on that graph you will see 


obviously the ratio between breathing zone air 


samples and general air samples. At the point 


where you start to look at that it’s the MPC 


level, you realize there’s a 70-some old 


discrepancy meaning that the BZ air samples 


will underestimate -- or the general air 


sample will underestimate a BZ air sample. 


And that’s just to give you an understanding 


of how rapidly an air concentration can change 


when you have very questionable source terms. 


Obviously, if we’re dealing with a 


nuclear weapon test like at NTS, the source 


term may be ground zero, and if you’re down 


wind by miles, the difference between position 


one that may be a few hundred feet and 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

192 

position two, is not going to be affected. 


But when you have a very, very discrete source 


term, even five feet, ten feet can make a 


monumental difference. 


And that is expressed in one of the 


examples that I cite where I think they took a 


sample six feet from a locations and it was a 


factor of five lower. But in this particular 


finding, 4.3-1, I also talk about the 


difference in air sampling that I looked at 


over a period of time and space, in time and 


space. For instance, in Attachment 4.3-1A you 


will see multiple samples that were taken at a 


single location, a single location and 


probably in a rapid succession. 


And on page 55, for instance, in that 


attachment you’ll see on the top page there 


were three samples taken. And among the three 


samples the high was 4,400 DPM per cubic 


meter, and the low was 170. And so you see in 


a single location over probably a very, very 


short time this huge difference that you can 


get in terms of air concentration. 


And I provide multiple examples that 


involve differences in air concentrations at a 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

193 

single location over a very brief time over a 


period of weeks, over a period of months or 


years, et cetera, et cetera, for common 


locations. And you get to understand the 


difficulty in trying to assign a single value 


to a person even when you understand what his 


job was and where he was stationed. 


And this is just a series of examples 


that I bring out here that defines the 


variability. We’re not talking percent value; 


we’re talking orders of magnitude values that 


will differentiate an air concentration. 


In fact, one of them was curious where 


-- I think it’s on page, I’m not sure. This 


is Attachment 4.1-A on the second page. I 


have actual values that are given in 


increments of minutes. And for this one was 


the location of west separation booth area, 


and you’ll see air concentrations taken at 


8:35, 9:05, 9:35, 9:50, et cetera. And you 


will see all of a sudden air concentrations 


that go from 42 to 333 to 140,000. 


You obviously realize that it’s a 


question of when were these spot samples taken 


that will define a person’s potential exposure 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

194 

to a certain air concentration. And I realize 


that at this point we’re looking air 


concentrations as the principal means of doing 


assessment of thorium exposures. And these 


particular attachments highlight the high 


degree of variability that you have to deal 


with in trying to define even when you do know 


a person’s job, and you also know where he was 


actually located in a given facility. 


MR. ROLFES: We are aware of the 


uncertainties associated with air sampling, 


but we feel that these uncertainties result in 


claimant-favorable intakes basically 


significant as overestimates in internal 


deposition. Given the fact that we’re not 


using any respiratory protection factors we’ve 


actually taken both breathing zone samples and 


general air, general area air samples. 


We’ve combined those basically to 


increase the data spread of the values. We’re 


using a distribution of those values to assign 


worker intakes based on an atomic weapons 


employer thorium intake model with information 


that has been analyzed by year for Fernald. 


Do you have anything to add to this? 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

195 

MR. RICH: That’s what I understood within 


the Health Physics community. As a matter of 


fact the number of reports, the little 


research and development little group I had 


did it one time. We took the breathing zone 


samples, the lapel samples on both lapels of a 


guy doing a (inaudible) cut of a, and the 


difference in the lapel sample breathing was a 


factor of five. 


And that’s the reason why AEC/DOE 


policy was that you would never use air 


sampling results as the primary result if you 


had anything else. Now what we’re talking 


about here is that you can be high as well as 


low in estimating results from samples here or 


there. You can be sampling, and so over a 


long, a database, a large database of air 


samples, particularly if it’s a lognormal 


distribution, and then default at the 95 


percent level, it’s always going to be 


conservative, always going to be conservative. 


And then one other thing. Based on 


long experience in the field we would take 


urine sampling, for example, based on the fact 


that there could be an intake based on air 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

196 

sampling data. And I don’t remember a case 


where -- well, I shouldn’t say a case. 


Occasionally there would be a case where you 


find urine activity that would be above what 


you’d predict with air sampling results. 


But at the 95th percent level, it would 


be, the air sampling results would predict 


uptake way above what was actually 


demonstrated by bioassay. So we’re aware of 


that. That’s all I’m wanting to say. 


DR. BEHLING: Well, the concern was also 


stated on context with the 1,050 MAC-hours as 


a model. And I’m sure you’ve looked at the 


attachments. There were a couple people who 


were cited for the air concentration, and it 


was noted he was not wearing a respirator 


where the air concentration was 1,260 NCGs. 


That translates to 1,000 rads. This guy would 


have gotten his yearly dose in less than a 


half hour or thereabouts. And so I just 


question the value of 1,050 as a default 


maximized intake value. 


MR. RICH: I think that we’ve already agreed 


that that approach may not be uniformly and 


assuredly conservative. We’re working that 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

197 

now. 


MR. ROLFES: Yes, exactly. Our previous 


default in the technical basis document was to 


assign 1,050 MAC-hours of exposure per year 


for a worker at Fernald. And we are actually 


reviewing, and I believe much of the work is 


already done in draft form. 


The amount of thorium exposure has 


changed based on the actual production and air 


measurements that we have recovered. And that 


is broken down by year and will be put into a 


model basically based on job, or worker 


category to assign annual intakes. 


MR. MORRIS: It doesn’t contain production 


data. 


MR. ROLFES: Okay, no production data. I 


apologize. It’s just air monitoring data. 


MR. RICH: It’s his work place assignment. 


MR. ROLFES: Exactly. We have it associated 


with plant and year. 


MR. RICH: Well, that’s at the craft level, 


too. 


DR. BEHLING: Because again, in one of the 


attachments, 4.3-1E, you see that there were 


two comparisons. The first data point 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

198 

involves May 17th through October 31st, and the 


other one was November 4th through November 


23rd
 . 


So two relatively brief time periods 


for the same location and the same area of job 


function, and you realize how different they 


are. I mean, just compare the two sets of 


data and you will be absolutely stunned by how 


things can change for a given worker, location 


and job function. 


MR. RICH: The initial effort in data 


capture for the initial technical basis 


document appeared to bound high, and as we 


uncovered more data, why, we agree. 


DR. MAURO (by Telephone): Mark, this is 


John Mauro. From your response in the matrix, 


it’s not clear given what I just heard you 


have data from different locations, perhaps at 


different times, and are you planning in your 


model to use the full distribution for a given 


location or building? Or are you planning to 


use the upper 95th percentile as your default 


value for intake? 


MR. ROLFES: We are using a Patel model that 


was put together. Let’s see, I’ll let Bob 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

199 

Morris comment on this also. 


MR. MORRIS: With regard to what air sample 


data we’re going to use, we’ve annualized the 


data and taken a lognormal distribution 


assumption around it and fitted the data. 


It’ll be, there’ll be parameters available at 


the 50th percentile, 84th percentile and 95th
 

percentile, available for dose reconstructors’ 


selection based on where they believe the 


appropriate model is for the maximizing or 


best estimated work used for that. 


The Patel model then allows input on 


the number of hours that the person worked, 


the job category that they had, whether they 


were an operator, maintainer, supervisor or in 


some other role, and I think that’s the set of 


parameters that (inaudible). 


DR. MAURO (by Telephone): So as I 


understand it, I did read 6001, so as I 


understand it, it’s up to the dose 


reconstructor to use his best judgment where 


within that distribution of values is the most 


appropriate for that particular case. 


MR. MORRIS: We’ll publish three values for 


each distribution, that’s right. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

200 

DR. MAURO (by Telephone): And they’ll make 


that choice, I guess, based on some guidance 


provided. 


MR. MORRIS: Yeah, also note that the reason 


our data spread so much and in a claimant 


favorable way increased the geometric standard 


deviation for the lognormal distribution is 


that we are combining breathing zone data and 


general area air sampling data. 


So it’s essentially two populations of 


data we’re treating as though they were one. 


An effect of that will be to spread the data 


and increase the geometric standard deviation 


and make the tail end of the lognormal 


distribution go higher than it might 


otherwise. 


DR. MAURO (by Telephone): Just one 


observation, since there is a substantial 


difference between whether you use, which 


percentile you use could change rather 


dramatically the assumed intake, and you’d 


like to make sure that those guidelines are 


used in a consistent manner, I don’t recall 


whether there’s any direction given on how 


does the dose reconstructor make that judgment 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

201 

for a particular case. Is there any general 


guidelines or it’s really left to his personal 


judgment on which of those three values are 


the one that is most applicable to a 


particular case? 


MR. ROLFES: Those guidelines will be 


published in the approved revision to the site 


profile. I don’t know if those, that verbiage 


is --


MR. RICH: The data’s in a tabular form so 


they can take it off the table. 


MR. ROLFES: The data as Bryce is saying, 


the data’s in tabular form and the dose 


reconstructor would have the option of 


basically choosing from a table. More details 


on this will be in the site profile document. 


MR. MORRIS: It just hasn’t been approved 

yet. 

MR. ROLFES: Yes, exactly. 

DR. MAKHIJANI: A couple of questions, a 


couple of observations first. One is in 


Hans’, in the document in review, you have the 


wet area. This came up earlier. This is a 


reminder for those of you who were not there, 


it also came up at Mallinckrodt where the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

202 

initial position was, oh, raffinates wet, low 


dose, don’t worry. And then the dose number 


that came out of NIOSH were actually quite 


high. 


The other point is that assuming 


respirator not used is not a claimant 


favorable thing. It’s just a factual thing. 


It says so in the document, no respirator worn 


at least twice that I’ve seen. And that’s 


just two points. 


The last observation that I have that 


I have a question is I don’t think mixing 


breathing zone samples and general air samples 


is a good idea. They all belong in the same 


distribution so methodologically it’s, you 


don’t have any distribution all you have is a 


collection of numbers. I don’t think you can 


call breathing zone samples and general air 


samples mixed up together a distribution in 


any rigorous in any statistical sense of the 


word. They’re two different sets of numbers. 


They’re taken in two different circumstances ­

-


MR. MORRIS: Well, also consider that we are 


proving these are lognormally distributed 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

203 

anyway. 


DR. MAKHIJANI: I understand all that. Just 


from the two different populations of numbers, 


they’re not the same thing. We just have gone 


through, you know, there’ve been lots of 


studies even where breathing zone samples can 


belong in some distribution, but at least you 


can say they’re in the same distribution 


because the measurements are the same thing. 


In statistics you cannot mix up 


numbers in distribution that are known to be 


from different populations. Moreover, within 


this process, we started, the very first thing 


we did was Bethlehem Steel. We had a long 


process in which NIOSH actually agreed not to 


mix breathing zone samples and general air 


samples, and agreed the general air samples 


actually needed an adjustment factor and that 


you could not mix these two things up. So 


just as a kind of a heads up that this 


procedure, even if it’s in an approved 


document, is a contradiction to other approved 


documents that NIOSH has approved. 


And my final question is, so I can 


kind of round this out, are you using the raw 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

204 

data with all of these numbers, high, low 


mixed in from all the different stations, or 


is there some daily weighted average 


proceeding? 


MR. MORRIS: We used every number that was 


available in the air sample database. 


DR. MAKHIJANI: Threw all the numbers into 


the pot without any consideration of how much 


time a worker spent in the operation? 


MR. MORRIS: That’s what biases the best 


year to the worst is that only the dataset we 


found for 1970 only had the levels of high 


values in it. 


DR. MAKHIJANI: Sorry? These are not the 


data that I’m looking at. On page --


MR. GRIFFON: Do we have this data yet? 


DR. MAKHIJANI: -- 55, I don’t know that we 


have the data, but we have quite a lot of air 


sampling data, and these are clearly data from 


various processes, and without a little bit 


more information you don’t know whether 


throwing in all the numbers into the same pot 


is going to be claimant favorable. I don’t 


know what the process is. 


Let me ask a question again. I mean, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

205 

we’ve gone through a lot of these things in 


previous reviews, and I don’t know what the 


process is to, whether the previous review 


matters in the new process. During 


Mallinckrodt we pointed out that if you have 


three measurements at a particular work 


location, and you try to create a daily 


weighted average out the average you’re going 


to find a wildly claimant unfavorable number 


because 95 percentile of the three 


measurements are going to be very high. 


If you throw all the numbers into one 


pot, you’ll get a very different result than 


trying to calculate 95 percentile at a job 


location and then weighting that with the time 


spent over there. So unless you have 


knowledge of the time spent actually you won’t 


know whether your result is claimant favorable 


or not in my opinion. 


MR. ROLFES: Let me give you an alternate 


scenario. Take, for example, a chemical 


operator that has a, that’s working, say, at a 


station working with green salt, and there’s a 


general area monitor right next to him. Say 


he’s doing his job and working for a couple 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

206 

hours, and he goes and takes a break. He’s 


away for 15 minutes. The meantime the air 


sampler is running so it’s going to continue 


to record air activity. 


Then again he’s going to be leaving 


for lunch, taking a shower, eating lunch, 


returning. Still that air monitor is going to 


be recording elevated levels of air 


contamination. So essentially, even though 


that worker isn’t being exposed during that 


time period, that air sampler is still running 


and recording data. 


So we feel that the distribution of 


both general area air monitoring as well as BZ 


data are, you know, all worth analyzing 


together. So we feel that both are, in fact, 


representative of worker exposures. 


DR. BEHLING: I would have to modify that 


because most of these sampling data are not 


controlled air samples. They are slot 


samples, and they will run for a matter of 


minutes. 


DR. MAKHIJANI: We have lunchroom data. You 


have all of that mixed in. 


MR. ROLFES: Sure, that worker could have 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

207 

been exposed in another area at an area of 


lower concentrations. 


MR. GRIFFON: Well, it sounds like all of 


this has been the spreadsheet. You’ve been 


analyzing it. I mean, once this is complete 


or is it complete and can it be posted on the 


O drive? I mean, I’d like to look and see. 


And I assume the descriptive part of it is 


kept in the spreadsheet so that we know which 


ones are BZ samples, which ones are general 


area. I think it might be useful for some of 


us to sort that out and see if we agree with 


your conclusions, you know. 


 DR. WADE: Do you have a question? 


MS. BALDRIDGE: I have a question. How do 


you address the issue like with the thorium 


levels being, the general air levels being 


three times the maximum allowable levels for a 


period of over three years continuously? 


MR. ROLFES: We would address that in dose 


reconstruction. We’re not making any argument 


to say that Fernald was a clean place at all. 


We realize that there were --


MS. BALDRIDGE: Well, I think Arjun had said 


about, you know, the time of exposure and all, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

208 

I was just wondering how that high a level 


over a continuous day after day after day over 


a three year period, what type of effect that 


has and how that is being factored into --


MR. ROLFES: Sure. We fully acknowledge 


that there were elevated air samples, and many 


of the air samples, they were very high. 


That’s very true. We’re not disputing that in 


any way, shape or form. And we’re basically 


using that information to credit workers with 


that exposure. So we’re not saying the 


Fernald was clean. There was no contamination 


at all. I don’t want to, you know, I don’t 


want to convey that message at all. 


MS. BALDRIDGE: I didn’t have that message, 


but I was just wondering about the extended, 


you know, when you’re talking about acute 


exposure, chronic exposure, that type of --


MR. ROLFES: Sure, exactly. If we have 


information saying that for three years this 


job was routinely a dirtier job that released 


more contamination into the atmosphere, we 


want to make sure that we are crediting the 


worker with that exposure. And essentially, 


it’s going to be a chronic exposure for those 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

209 

three years, so that’s what we’ve tried to do. 


In this data that we’ve collected for 


thorium, we’ve taken all these samples, put 


them together by year and run a statistical 


analyses of these data points to come up with 


a likely value but also uncertainties 


associated with that most likely value. And 


we want to make sure that we are claimant 


favorable in assigning intakes because we know 


that respirators were supposed to be used, but 


they weren’t routinely. 


So we’re not going to, what we see in 


the air, we’re going to assume that that air 


concentration is what the worker was exposed 


to. We are not going to apply any respiratory 


protection factors, and we will, in fact, 


assume that the worker was exposed to what was 


measured. Did I answer --


MS. BALDRIDGE: That was fine. 


MR. GRIFFON: I don’t know that we can go 


much further without seeing the model itself, 


but I did have one follow up on 6001 because I 


haven’t looked at that procedure. You 


mentioned that two factors could be added in 


from the Battelle model, one was the hours 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 -- 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

210 

worked, but also the job type. And is that 


really referencing back to what was in? 


You’ve got a table of different types of job 


categories with different -- I don’t 


understand how you entered the job type into 


this model. I’m trying to --


MR. MORRIS: It’s just a number factor. One 


hundred percent of the doses assigned are the 


intake. It’s assigned if you’re an operator. 


MR. GRIFFON: Okay, so it’s based on 


maintenance operator versus administrative or 


MR. MORRIS: That’s right. 


MR. GRIFFON: -- and some fraction applied. 


MR. MORRIS: Yes. 


DR. BEHLING: The finding number 4.3-2, I 


think, has been addressed because it also 


raises the issue of the 1,050 MAC-hours as a 


default value. 


So to Finding 4.3-3, and that one is 


titled limitations associated with the use job 


tasks, job locations for the assignment of 


thorium intakes. And we just, in fact, Bryce 


has just mentioned that the new model will try 


to define by year the job function and base 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

211 

air concentrations and intakes on those two 


parameters, job function and by year. 


In going through the documents I 


identified a number of references to a project 


labor pool, rolling maintenance crew, roving 


operators and also enclosed a couple memos 


that were submitted by the Director of the 


Health and Safety Division in ’53 who 


complains about the fact that when he gets a 


person in there, he doesn’t always know. He 


thinks he knows, but then it turns out that 


the card or the data that he has is incorrect, 


and I quote here, and he makes reference to a 


roving maintenance man. 


He said, the department of the job 


location is where they present themselves for 


medical care. The man then reveals that he’s 


working in a different area from the one noted 


on his medical records. In a subsequent memo 


it’s written that another serious problem in 


determining internal exposure is the 


difficulty in good work records which show how 


long an individual worked in the various jobs. 


So again, we may have information that 


would designate a person to a different 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

212 

location, a different job function, but he may 


not necessarily be there. And then there are 


people, and they’re not small in numbers, that 


are labeled as project labor pool. 


And they may have had some of the 


dirtiest jobs including repackaging drums. 


They were constantly involved in some of the, 


probably the most difficult and highest 


airborne environments. And do we have any 


clue as to who these people were? Are they 


identified as members of the labor pool, 


members of the roving maintenance or roving 


operators? And when there is no such 


designation in their file, what do we do about 


these people? 


MR. ROLFES: I think we sort of addressed 


that a little bit before, that we don’t feel 


this is an SEC issue because we have a model 


to essentially assign intakes based on the 


Battelle AWE model. With real data from 


Fernald we’re using a model for different 


classes of workers, for operators, for 


laborers, for supervisors. 


DR. BEHLING: But you will have to obviously 


make some decision as to which category the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

213 

95th percentile comes from. 


MR. HINNEFELD: Part of the process, I 


think, that has to come out in our next 


response to this is not only the basis for the 


model we intend to use, but some idea that 


what can we select of the worker population to 


which this model would be used for. I don’t 


think we can just say that, well, we have a 


way to do it to take some people and assign 


them to put them in this population that we’re 


going to assess their dose in this manner 


without accompanying that with a set of 


decision criteria for what employees fit with 


that. I think that’s part of the same 


analysis we’ve talked about. 


DR. MAKHIJANI: I’d just like to mention 


fugitive emissions again. I think if you just 


take a look at that one memo from 1970 which 


is quite late, and try to infer the kind of 


dust levels that would have motivated the 


writing of that memo. 


MR. ROLFES: (Inaudible) version? 


DR. MAKHIJANI: TBD review. I’ll just read 


it. I read the bucket brigade piece earlier, 


and then there’s another piece where the ball 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

214 

mill was leaking, and there was dust 


everywhere. And then the second piece to that 


memo, Ross, 1970. 


“During the operation of removing the 


calcine, thorium, tetrachloride and calcium 


fluoride from the retorts, the stack-up tray 


is left standing on a skid near the south 


annex door. The door is left open to aid in 


pulling the trays. The winds coming through 


the door blows the loose powder from the trays 


and spreads it generously through the annex.” 


And, you know, while we say we are 


doing generous dose reconstructions, there’s 


no measurement of what this generously through 


the annex means. You’ve got this blowing 


inside and outside, and this is why I said 


that you can have non-production personnel get 


quite high exposures in very short periods of 


time. You walk through something like that 


and a gust of wind, and you’re essentially in 


a little bit of a thorium dust storm. 


And because the stuff was there at 


open doors as late as 1970, and you wonder 


what happened in 1956 and 1955 and 1954 when 


stack emissions were at least -- you know, I 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

215 

can’t remember the order of magnitude higher, 


but it was a lot higher. I don’t see how 


you’re going to use any of these models which 


have to do with production data to take into 


account fugitive emissions or who was exposed 


or put a limit on this. 


MR. ROLFES: It doesn’t sound like that was 


necessarily blowing outside. To me it doesn’t 


differentiate whether the materials were 


blowing back into a production area --


DR. MAKHIJANI: It would depend on whether 


the wind was coming from the inside to the 


outside or the outside to the in. And I don’t 


think you have the measurements to say that, 


and so you have to assume it was in both 


places some of the time. 


MR. ROLFES: So if the material was blowing 


back into the production area, it would have 


contributed to the observed air monitoring 


data that we have. 


DR. MAKHIJANI: And the other way about? 


MR. ROLFES: And the other way about? If we 


don’t have information, we’re actually going 


to assign the highest annual intakes in our 


model. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

216 

DR. MAKHIJANI: The question is how do you 


know that the highest assigned intake covers a 


situation for which you have absolutely no 


evidence that you have any data? 


MR. MORRIS: It’s possible that the 


concentration outdoors is lower than the 


concentration indoors. 


DR. MAKHIJANI: Well, you know, it’s a 


question. What plausibility in the scientific 


sense has to be buttressed by at least a few 


data points? And I’m not aware of data 


points, at least in regard to thorium, that 


are there for fugitive emissions, and you can 


say that this is a pure speculation that there 


was a sampler near where the trays are being 


dried. 


And I have not seen any reference to a 


sampler near a door where trays are being 


dried. So you don’t have any evidence that 


you have an indoor air sample. I’ve looked at 


a lot of air samples, and I have not seen 


evidence of any. 


I readily grant you if they were on 


the other side of it. You don’t have any 


outside air samples. Do, in fact, do we know 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

217 

of a high dust operation with indoor and 


outdoor contamination for which you have no 


samples at the time it was documented in 1970, 


not to speak of the time in 1950s when such 


things may not have been regarded as worth 


documenting. 


MR. ROLFES: It’s important to differentiate 


where we’re going with this because for 


uranium exposures, for example, we wouldn’t be 


relying on the air monitoring data. That 


wouldn’t be as important to us. The 


urinalysis data would be the most important 


piece of information. 


DR. MAKHIJANI: I agree. 


MR. ROLFES: Thorium is slightly different 


though because they did, in fact, have 


different attempts to take thorium bioassay in 


the early days through urine. It wasn’t a 


very good method so they didn’t follow through 


with it. What we have done I believe is very 


claimant favorable because we are accounting 


for production of thorium by year, and I would 


have a hard time believing that the outside 


thorium air concentrations were in excess of 


the actual production operation. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

218 

DR. MAKHIJANI: Inside. Do you have any 


evidence that there was a single air sample 


taken near the door where these trays were 


being left to dry and it says, “removing the 


trays from the support requires heavy effort 


and this dislodges more powder to be spread by 


the wind.” There’s no evidence that there 


ever was a single air sample over 20 years. 


MR. ROLFES: We can discuss it either way, 


but, you know, we can’t go on asking questions 


about what data we don’t have. You know, 


that’s, we are focused on the data that we do 


have, and that is what we have analyzed. And 


we do feel that this is claimant favorable to 


assign intakes based on the recorded data 


associated with the production operations. 


MR. HINNEFELD: Well, I mean, the air 


sampling data has to be compiled and presented 


to the work group. And it will either be 


convincing or not as to whether it has covered 


the appropriate places and is of sufficient 


number. So, I mean, we can talk here all day, 


but until the working group sees the data, 


it’s not going to matter. 


DR. MAKHIJANI: I wasn’t talking about the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

219 

sufficiency of the data. I just am flagging 


this as being a very remarkable thing from the 


first time I looked at Fernald data which is 


about 20 years ago actually the first time. 


And this has been a very remarkable thing 


about this site is that the ambient, what is 


normally called ambient environmental 


contamination I believe at Fernald in many 


places was dominated by this kind of fugitive 


emissions. 


We had blowouts, you know, and stuff 


coming out of the windows. You had stuff 


drying in the doors, and so the stack 


emissions even though they were high, may not 


even describe a fraction of this kind of dose. 


And I just think that methodologically it’s 


extremely difficult and should be flagged and 


attended to because I have not seen any other 


site with this kind of problem except, you 


know, in the context of nuclear testing or 


something. 


RADIOLOGICAL THORIUM INCIDENTS
 

DR. BEHLING: We’ll go to Finding 4.3-4 on 


page 70. And this is basically a continuation 


of the issue surrounding the difficulty in 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

220 

quantifying the air sampling data. And this 


particular finding is entitled the inability 


to account for internal exposures associated 


with radiological thorium incidents. 


And it’s well documented, and it’s 


also accepted by NIOSH that small fires, 


spills, explosions were commonplace. And yet 


it is unlikely that most of the air sampling 


data that you’re compiling will necessarily 


reflect them, those radiological incidents. 


So that you have a large number of readings 


from air sampling that you may have at 


specific work locations. 


But those were spot samples, some as 


short as a few minutes at a time. You don’t 


have any kind of understanding of radiological 


incidents and what airborne concentrations 


they may have contributed to. And as part of 


the attachments there was one that first you 


talk about the number of known fires and all 


the different, the (inaudible) nature. 


And let me just recall that much of 


the work at Fernald was very much similar to 


what had taken place at Ames, that is, the 


reduction of thorium. And we all know how 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

221 

dangerous that particular process was in terms 


of the exothermic reaction that resulted in 


blowouts and large releases of thorium. 


But the one particular attachment I 


wanted to look at was Attachment 4.3-4D. It’s 


on page 76 of the report, and it just caught 


my eye when I looked at that because it turned 


out that perhaps just a, there were air 


samples taken that were at a location where 


thorium was being processed. And the first 


general air sample that we see as the first 


entry, I believe -- I may have marked those 


with arrows -- were basically background. And 


you have a high, low and, I guess, average 


value here. 


And in the next one it says, “same as 


above except” -- it’s hard to read -- derby on 


fire, “one derby on fire.” And they took two 


air samples. And it goes from, I believe, 


yeah, it goes from an average of 2.1 MAC as 


background before the fire to 458 MACs. And 


it happens obviously in an instant. 


And in this case there was somebody 


there to observe what the air concentrations 


were at the time of this one derby fire. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

222 

Further on I think there was another instance 


where there were two derby fires occurring 


simultaneously. 


And it just demonstrates the 


ubiquitous nature of radiological incidence 


and the very rapid rise in air concentrations 


to which a person may have been exposed to 


that are probably not likely to be captured by 


spot samples that are normally taken based on 


the fact that industrial hygienists in today’s 


job is to go down there and just routinely go 


through there. 


And it’s not always likely that he 


would catch these radiological incidents that 


we know will raise the air concentrations by 


orders of magnitude. So this is just another 


variable that is probably not going to be 


accounted for in trying to model air 


concentrations for dose reconstruction. 


MR. ROLFES: Hans, this appears to me to be 


a uranium derby rather than a thorium metal 


product. And for uranium this isn’t of 


concern to us because of the bioassay data. 


DR. BEHLING: Well, okay, if it was, I 


wasn’t really sure. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

223 

MR. CHEW: It does not say thorium. I’m 


looking at it now. It just says derby fires. 


DR. BEHLING: Yeah, it just says derby 


fires. But again, the question is that would 


it matter? It’s likely that derby fires 


involving thorium also occurred for such 


exposures. 


MR. CHEW: But there was no such thing as 


thorium derbies, right? 


 MR. CLAWSON: No, uranium derbies. 


DR. BEHLING: Only uranium? 


MR. CHEW: Derbies are related to uranium. 


DR. MAKHIJANI: There were 30 drum fires, at 


least 30 known fires until 1959 in materials 


involved in thorium residue. I don’t know. 


Do we have any data for those thorium fires? 


This is on page 44 of the review. 


MR. ROLFES: A big fire that occurred was an 


accident that resulted in the death of two 


employees. Two employees received severe 


burns in 1954, I believe, at Plant 9 during a 


blending operation where they were combining a 


calcium metal with some thorium tetrachloride, 


I believe it was. And I guess there was a 


little bit of excess moisture in the thorium 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

224 

material and it reacted with the calcium metal 


and caused an explosion. 


We recognize that events like this did 


occur, and I’m hesitant to say I don’t recall 


seeing air sampling data specifically 


associated with that occurrence. But I would 


have to take a look. 


DR. MAKHIJANI: I was asking about the fires 


actually, Mark. They were documented from 


1959. It says, “During the past four years 


there have been 30 known fires with these 


materials.” Thorium and -- “some of which 


burned for several days. Clean up after these 


fires is a difficult job. In one case the 


fire burned through a concrete storage pad,” 


et cetera. Housekeeping problem, hazards, 


with residues and unoxidized (inaudible). 


So you’ve got a systemic problem here 


for a number of years that has gone on, and 


these drums were presumably stored outside. 


Correct me if I’m wrong. These things were 


stored outside at Fernald to my knowledge. 


And so you’ve got workers probably involved in 


putting out these fires and cleaning up the 


residues that would have been exposed to 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

225 

thorium. 


First of all it would be good to know 


if we have some data on who these workers 


were. And secondly, if there are any data to 


support the dose reconstruction with respect 


to incidents like this with thorium. 


MR. ROLFES: Sure. I’ll address this 


generally at first. I don’t know for a fact 


whether we have air sampling associated with a 


short-term excursion or a short-term episodic 


release for thorium outdoors. I haven’t taken 


a look, and I can’t recall from the thousands 


of records that we’ve recently catalogued and 


recovered. 


However, when we’re discussing intakes 


from acute scenarios, NIOSH is not intending 


to do intakes of this approach in a dose 


reconstruction for thorium. What we’ll be 


doing is a chronic intake, and I think in 


almost all cases that we’ve discussed with 


SC&A, we’ve been able to demonstrate that 


these chronic intakes are generally more 


claimant favorable by assuming that the worker 


was continuously exposed over a full 2,000­

plus hours per year rather than breaking it 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

226 

down for a short duration exposure to a very 


high air concentration. I believe that our 


methodology has been claimant favorable in 


assigning intakes from these scenarios. 


DR. MAKHIJANI: That’s not always the case, 


and moreover, you have to be able to identify 


the worker in a production situation where you 


have (inaudible) and a record of an incident 


and continual exposure you can do something. 


But if you don’t know who the worker is, and 


you don’t have a record of any continuous 


exposure, and you have a single incident 


intake, and you don’t know when to assign it, 


this is more of a problem. 


MR. ROLFES: If we have indication that a 


worker was involved in thorium operations 


based on information from a telephone 


interview, based on information from a report, 


based on dosimetry records which would 


indicate which plants the individual was 


working in, then we can certainly associate 


that worker with potential exposures that were 


ongoing in that plant or that area during that 


time. So the more data that we have, 


obviously, the better detailed, more accurate 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

227 

and precise approach that we can take for a 


specific claim. However, typically, when we 


have less information, we are more claimant 


favorable in assigning dose. 


DR. MAURO (by Telephone): Mark, this is 


John Mauro. The data that’s collected, the 


air sampling data, I would say for a given 


building or room of thorium, was that a 


continuous air sample that was continuously 


collecting air particulates over the course of 


the day, day-in, day-out throughout the course 


of a year or was this some type of spot 


samples that were taken at different time 


periods? 


I guess the only reason I ask that is 


that a human being is for all intents and 


purposes a continuous air sampler. So in 


effect if you have a continuous air sampler 


always collecting it so you get a time 


integrated accumulation of what was the 


airborne activity over the course of a year. 


I know you might pull the sample after it gets 


loaded up and replace it with another one, and 


I understand that over a long period of time 


there may be these short-term spike that we’ve 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

228 

been talking about, if they are short-term. 


They all sort of average out. 


So I guess I want to get a better feel 


of the air sampling data that was collected 


for thorium. When was that? Were those 


continuous air samples? 


DR. BEHLING: No. 


DR. MAURO (by Telephone): They were not. 


MR. ROLFES: That was Hans, but I’d like 


Morris to answer this, please. 


MR. MORRIS: No, they were generally 30­

minute air samples that were taken in 


triplicate by Industrial Hygiene technicians. 


There was a standard operating procedure 


published in 1960 that clears what we think 


HASL imprinted on the plant in the early ‘50s 


as a method. And it looks as though that was 


probably the procedure that was followed 


through the duration. 


DR. MAURO (by Telephone): For example, this 


30-minute air samples that were collected now. 


They were collected once a day? Were they 


collected just a few times during the course 


of a year? Just trying to capture, given what 


I heard as variable air concentrations from 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

229 

place-to-place and time-to-time, and then 


someone comes in and grabs a 30-minute air 


sample let’s say once a day. That might be 


okay. 


MR. MORRIS: John, I don’t think it was as 


clear cut as that. In 1954 we had 530 samples 


recorded, 750 the next year and 225 the next 


year. ‘Fifty-seven, ’58, ’59 I found no data. 


But, of course, in those years there was very, 


maybe no production at all going on in 


thorium. ‘Fifty-seven there probably was. 


I’m not sure. 


MR. RICH: Let me add just a note, too, and 


that is that the uranium production involved 


thousands of metric tons and large amounts of, 


large masses of uranium going to the plant all 


the time. In the case of thorium, however, it 


averaged considerably less than a metric ton 


per day. 


And so the process was not only short-


term -- and by the way, a metric ton is a 


piece about like so. It’s very dense 


material. Now, it’s a bigger volume because 


if you get thorium oxide then, of course, the 


average density is considerably less. But for 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

230 

a perspective standpoint, the thorium 


operation was not like uranium by several 


orders of magnitude. And so when we talk 


about continuous samples the operation was 


probably not continuous. It was a batch-type 


operation in general. 


And so these samples, although they 


may not sound like much, and the general air 


samples of 30 minutes may not sound like a 


continuous air or a very good general air 


sampling for this particular operation, they 


very well could have been appropriate for 


general or breathing zone samples and 


monitored as the process was in place. 


DR. ZIEMER: Were they systematic --


MR. RICH: By the way, we’re going to find 


out a little bit more about that in some 


interviews we have scheduled with some 


professional people. 


DR. MAKHIJANI: From the bone dose point of 


view if you just want to take the kilograms 


and move from kilograms to per Becquerels, the 


bone surface dose for Thorium-232 is nearly 


three orders of magnitude bigger per 


Becquerel. So the production is two orders of 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

231 

magnitude less of the dose per Becquerel. 


MR. RICH: What we’re talking about though, 


Arjun, is not that conversion factor but the 


definition and the concept of general air 


sampling or how you’re monitoring a given 


operation. 


DR. MAKHIJANI: What you’re saying actually 


makes it more difficult to do dose 


reconstruction because if you’ve got a small 


volume of material with very high dose 


consequences, three orders of magnitude bigger 


almost for one organ at least, then you’re 


sampling network has to be considerably more 


dense than when you have a large volume of 


material going through the same big building. 


Because thorium was going through the same 


buildings as uranium, and the buildings were 


designed for uranium. 


There’s no question that uranium was 


the main thing, and it was two orders of 


magnitude more than thorium, but you have a 


sampling network and a sampling protocol. And 


buildings which are designed for a mass volume 


of material, and then you’re dealing with a 


smaller mass of material with much higher dose 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

232 

consequences. So how are you, you know, these 


general air samples, even if you accept the 


breathing zone designation at face value, I 


think the problem of general air samples with 


thorium is going to be much more complex. 


MR. RICH: The sense we have from looking at 


the air sampling data at this point is that 


they were taken operationally specific, 


specific to the individual operation, a 


breathing zone of a person actually doing a 


job or general air sample in the vicinity of 


the specific operation that was being 


conducted as opposed to a continuous operation 


for two shift, you know, or whatever. 


DR. ZIEMER: Well, that answers my question. 


They’re systematic in terms of jobs rather 


than time of day. 


MR. MORRIS: And they’re spread over a first 


and second shift. 


DR. ZIEMER: Although the mass is much 


smaller, your specific activities are much 


higher. 


MR. RICH: Specific activity for thorium is 


much lower. 


DR. MAKHIJANI: Lower by about a factor of 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

233 

three, but the dose conversion factors are 


much higher. 


DR. ZIEMER: For the dose conversion 


factors, yeah. 


DR. BEHLING: You mentioned something that 


we may get in later if we get that far, but in 


one of the affidavits that was a sworn 


statement given by an industrial hygienist. 


And it’s included in here, he made mention of 


the fact that the industrial hygienists never 


worked other than the first shift Monday 


through Friday not on weekends, second and 


third shift. And it was known to people that 


they would postpone the dirtiest jobs when the 


industrial hygienists weren’t there. You 


mentioned that there are air sampling data 


that identify the second shift. Is that a 


fact? 


MR. RICH: Yes. 


DR. BEHLING: Do we have that for most of 


the years? 


MR. MORRIS: When you look at air sample 


datasets, you see that there’s a lot of them 


that start at eight or nine o’clock in the 


morning, and there’s a lot of them that start 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

234 

at four or five o’clock in the afternoon. 


It’s as though the system, the second shift 


crew came on and got their equipment ready and 


started the air samples. So I would almost 


guess that there’s as many second shift as 


first shift. 


MR. GRIFFON: So the, I mean, the data you 


provide, the spreadsheets going to have all 


this information, location, time, time of 


sample, volume, culture. 


MR. MORRIS: I think so. I’m not going to 


know what the spreadsheet says. 


MR. GRIFFON: As much detail as you have 


anyway. 


MR. MORRIS: Certainly the raw datasheets 


will show the time of day that it was taken. 


DR. BEHLING: It would certainly conflict 


with the testimonial statements given by that 


individual I made reference to because he 


distinctly made reference to the fact that 


industrial hygienists worked only Monday 


through Friday on first shift. It would be 


very helpful to dispel that if you have data 


that would contradict his comments. 


MR. GRIFFON: But air sampling is so 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

235 

(inaudible). 


MR. MORRIS: All the air sampling records 


are available to see hard copies. 


 MR. CLAWSON: A lot of this, we can debate 


this for quite awhile, but a lot of this until 


we get to be able to see the data we’re going 


to have to be able to do our own thing. So 


unless there’s some critical -- I don’t want 


to stop anybody, but if we can go on. 


THORIUM PRODUCTION
 

DR. BEHLING: Let’s go on to 4.3-5 on page 


77. And I just, Arjun will take that one. 


DR. MAKHIJANI: I think we’ve already 


discussed it, and from what I read in your 


response that you have a lot more data on 


thorium production than you did in the 


facility years because at this point there are 


lots of gaps in the data. So I guess there’s 


more data that we need to look at. 


MR. ROLFES: Yeah, we initially thought this 


could be an SEC issue, but we feel that the 


additional data we’ve collected and analyzed 


consequently no longer make it an SEC issue. 


DR. MAKHIJANI: Yeah, so I guess we just 


need to see the data. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

236 

RE-DRUMMING
 

DR. BEHLING: The next one is on page 86, 


4.3-6. 


DR. MAKHIJANI: The post-production period, 


well, what happened in the third period, the 


re-drumming. 


MR. RICH: That was even during operational 


periods. 


DR. MAKHIJANI: Well, there was a lot of re-


drumming during operations. 


MR. MORRIS: Three years from what we 


understand from the report. 


DR. MAKHIJANI: There’s a question of the 


re-drumming during the operations, and then 


there’s this gap between ’77 and ’86 when you 


have lapel sampling. And I did not see any 


information as to how that dose reconstruction 


was going to be done. At least we had residue 


of contamination, you have re-drumming 


operations, you have, you know, you have a lot 


of different, you have stuff that we dumped 


into the pits, stuff we’ve shipped in and out 


as part of Fernald being a repository for 


thorium. Or shipped in maybe. But I don’t 


know, I have not seen any data from that 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

237 

period separate from the re-drumming question. 


 MR. SHARFI: The post-production period is 


after the in vivo, the thorium was up and 


running, right? So you would have thorium in 


vivo counts for the workers for the postproduction periods. So you can use actual 


monitoring data rather than air monitoring 


data. 


DR. MAKHIJANI: In vivo counts for the 


thorium did not stop in ’78 or whenever --


MR. ROLFES: From ’68 through ’88 and then 


on after as well. 


MR. MORRIS: And then with a new system that 


was installed at the plant in ’88 or ’89. 


DR. MAKHIJANI: So I guess with that, too, 


we have to just wait for that. 


MR. ROLFES: Sure, that is an important 


point that we sort of skipped over a little 


bit. We do have thorium air monitoring data 


that we’re going to use; however, we also have 


the mobile and giga-radiation monitoring 


laboratory results from 1968 through 1988. 


Those have all been transcribed and analyzed, 


and we can actually basically take a look at 


those in vivo data and ensure that our thorium 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

238 

air monitoring data is in fact claimant 


favorable and also reasonable. 


DR. MAKHIJANI: And how about the re-


drumming operations? Do you have for the 


early period air concentration data for that? 


MR. MORRIS: We may. It’s hard to know for 


sure whether we’ve got enough. You know, 


we’re only now getting focused in with the 


right people to tell us when the re-drumming 


happened. That was kind of a detail that we 


didn’t understand, so we’re correlating when 


they said something happened now and going 


back to try to find any air sampling records 


is something we’re working on right now. 


DR. MAKHIJANI: The next one is re-drumming 


(inaudible). 


DR. BEHLING: Yeah, and I guess I’m not so 


sure in looking at this, when a facility goes 


from thorium production back to uranium, are 


people at that point monitored principally by 


urinalysis, which is now your focus regarding 


their uranium exposure? 


MR. MORRIS: No, the equipment was cleaned 


in between the campaigns. 


DR. BEHLING: Because one of the things that 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

239 

was introduced here was the transition period 


where, okay, today we stop processing thorium, 


and we’re now back into uranium production. 


The question now is what do you monitor for, 


uranium by way of urine analysis or thorium by 


way of air monitoring? Because clearly 


residual contamination must have or persistent 


contamination must have continued for some 


period of time. 


MR. ROLFES: There were limits on the amount 


of contaminants that could be contained within 


uranium metal. There are documentation of any 


contaminants in the thorium metal so they 


would have wanted to clean the machines if 


they were used for the same, or used for 


thorium then for uranium. 


I’m sorry, what was the other part of 


your question then, Hans? 


DR. BEHLING: Well, the question is how do 


you monitor people during this time period 


where yesterday you did thorium; today we did 


uranium? Did they monitor for urinalysis or 


do we monitor continual air monitoring for a 


period of time? Because we know very well 


there’s persistent thorium levels, 

1 

2 

3 

4 

5 

6 -- 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

240 

contamination levels that people were exposed 


to during this period of time. And the 


question is what do you do? 


MR. ROLFES: For the production years, are 


we going to be assigning an entire year intake 


So the entire year of intake will be 


assigned by year. So we won’t be addressing a 


lower intake potential for residual 


contamination but rather a production-level 


intake for the entire year. 


MS. BALDRIDGE: I have a question or 


statement. In, I don’t recall which document, 


but when the auditors came in to check, I 


think there were some came in from Oak Ridge. 


And in those documents it talks about the 


questioned whether some of this in vivo 


testing that was being done on the individuals 


were being done correctly. They also said, 


you know, then, I guess, this transition time 


from one product to another, they came in five 


years later. There was still contamination 


that had never been dealt with. 


MR. ROLFES: Sure, that’s, once again, we do 


understand that Fernald had contamination. We 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

241 

understand that. We, we --


MS. BALDRIDGE: I just think it puts a 


question on the reliability of the data that 


they’re presenting from their in vivos if the 


auditors questioned how competent they were to 


even administer or evaluate the information. 


And it was all done in-house so no one was 


ever checking what was done. 


MR. ROLFES: We’ve spoken with the people 


that operated the mobile in vivo radiation 


monitoring laboratory equipment. And, yes, 


they did have procedures to calibrate the 


equipment. They did do routine quality 


assurance checks on the equipment. I don’t 


believe we have the procedures at this time. 


I know that a couple of the people that we 


have, in fact, spoken with though could verify 


that there were quality assurances to ensure 


that they were getting good data essentially. 


MR. GRIFFON: I think I just captured that 


as an action item. Maybe that you should look 


back at the audit report that --


MR. HINNEFELD: Is this document in the 


petition? 


MR. GRIFFON: -- just as a reference to 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

242 

that. 


What is it? 


MR. HINNEFELD: I just asked if this 


document was with the petition and so we can 


go find it, and we can address what’s in that 


document. 

MR. GRIFFON: Yeah, address that. 

THORIUM INGESTION 

DR. BEHLING: We’re going to skip the next 

two findings because in discussing it between 


Arjun and I, I think we’ve discussed enough 


issues surrounding Finding 4.2-7 and 8. So I 


think we’ll go to Finding 4.2-9 on page 93. 


And the title of that finding is the inability 


to assess internal exposures from the 


ingestion of thorium. 


And we kind of thought about what are 


the potentials for exposure due to ingestion 


pathway given the fact that repeatedly we see 


things such as one of the words housekeeping 


situations that were encountered. We have 


people who were not properly trained about the 


avoidance of certain practices such as 


touching your mouth or certain other things. 


We know that they were not given anti-cees*. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

243 

They were probably never really monitored for 


fecal analysis that might have perhaps 


assessed their intake by way of ingestion, 


especially for insoluble materials that would 


nevertheless expose the cells of the GI tract 


during the transit time. So the question is 


there are gaps here with regard to how do we 


model the ingestion of thorium exposures in 


the absence of data that might provide us some 


clue. 


MR. ROLFES: And we’ve alluded to this a 


little bit in our discussion of the atomic 


weapons employer thorium exposure model 


developed by Battelle. We’re going to be 


using thorium air monitoring data within this 


Battelle model. And it also evaluates, or 


also included intakes from ingestion, from the 


ingestion pathway. 


MR. MORRIS: That’s based on the OCAS 


guidance that came out of mode two and mode 


three in testing. Battelle incorporated the 


OCAS directives. 


DR. BEHLING: So the new model will address 


ingestion? 


MR. MORRIS: Explicitly. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

244 

DATA INTEGRITY FOR AIR MONITORING
 

DR. BEHLING: The last one on this one is 


the issue of data integrity for air 


monitoring. And I did make reference to, and 


briefly touched on moments ago, the affidavit, 


the sworn affidavit that was provided by an 


industrial hygienist regarding what he recalls 


during the 17 years of employment there. And 


then he cites a number of issues here that 


obviously you speak disparagingly about some 


of the practices inclusive of things that he 


was asked to do by his superiors. 


And I always look at statements like 


this, and I’m currently, and I won’t go beyond 


what I’m about to say, and I always look at 


the source. And it’s like a crime 


investigation. You sort of say who’s got 


reasons to say what. And sometimes you 


realize you’re dealing with disgruntled 


employees for one reason or another, and it’s 


unreasonable to assume that in some instances 


this is strictly very biased at best and an 


outright lie at worst on the part of that 


individual. 


But in this case I have to look at it 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

245 

and sort of say how much truth is there. 


We’ve already discussed the issues where he is 


going on record and stating that they never 


took air samples on the second and third 


shift, neither that or on weekends. If you 


can prove that, certainly that would be one of 


the issues that could be put to rest. But he 


talks about air sampling protocols where he 


was asked to go back again and again and again 


until he came up with air sample data that 


somehow or other met the expectation of his 


superiors because they were under the gun to 


clean up the act and keep production rolling. 


And so I guess I have to look at this 


guy’s statement and dismiss it and take it 


very seriously that after all, it’s not a 


moment in time. It’s not a single incident. 


It’s 17 years worth of employment, and he has 


some very critical statements to make here. 


MR. ROLFES: In the case what he had 


described was that he had taken a couple of 


air samples, reported them back to his 


supervisor, and he supervisor said, you know, 


those couldn’t be that high, go take more 


samples. So it essentially attracted the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

246 

supervisor’s attention to those high airborne 


results. So the individual went back, took a 


couple more samples, still got some high 


results, reported them to his supervisor. No, 


those can’t be right, you know, something’s 


going on and attracted his attention once 


again. So this individual, you know, rather 


than walking away from an observed high air 


concentration value where they might have a 


problem, the individual was continuously sent 


back to that, to take additional samples to 


determine what the problem essentially was. 


Keep in mind that the data, we don’t have any 


indication that the data was destroyed. I 


don’t know what specific set of air sample 


data this individual was referring to or if 


there’s some specific results, but there’s no 


indication that the results were not reported 


in the record or that NIOSH couldn’t get them. 


MR. GRIFFON: That may be one of the things 


I was talking about earlier. If this 


individual had logbooks, then if we could find 


the logbooks related to the time period that 


he worked or his logbooks or whatever and 


compare them back to the data you have. And 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

247 

if all the data is there then I guess it shows 


that they weren’t, you know, just trying to 


get a clean result. They were --


DR. ZIEMER: Well, certainly a follow-up 


survey would make sense, and I guess the issue 


now is --


DR. BEHLING: Well, it’s who do you believe. 


DR. ZIEMER: -- is he being sent back to get 


better results or --


DR. BEHLING: Yes, well, that’s the crux of 


the issue, I think. I sort of alluded to the 


fact that maybe the culprit here is the 


hygienist who then, in order not to go back a 


fifth time, decided, I’m going to give them a 


low dose and then they’ll be happy. 


And the statement that he incorporates 


if you read his verbatim statement is that the 


rejection of the high values were based on 


their unacceptability because the person as 


his superior did not want to acknowledge the 


fact that the air concentrations were that 


high. Mark sort of thinks that his superior 


was so concerned he kept sending him back 


again. It’s a question of who’s the culprit 


here. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

248 

MR. RICH: Well, you know, as Paul 


indicated, from my operational experience if 


you get a high sample, you normally want to 


investigate the source of the result, send 


back the, find out what the source is or to 


see if you can fix it. 


MR. GRIFFON: Well, you can read it both 


ways. 


MR. RICH: You can take a series of samples. 


MR. GRIFFON: You can read it both ways. I 


mean, you could say I don’t want to shut down 


the operation. Go back and get a clean 


sample. I’m not shutting things down. 


DR. BEHLING: I agree with you, but 


repeatedly if you read these memoranda is that 


the issue over and over and over again from 


industrial hygienist says we need better 


engineering designs improving the ventilation 


system. And it’s not up to the industrial 


hygienist to rectify the problem. He’s only 


there to be the bearer of bad news. That’s 


all he is. He’s the messenger. He shouldn’t 


be shot for bringing back the bad news. 


The people who should have had the 


incentive to change the ventilation system or 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

249 

create barriers or do other things were people 


that were outside his purview. So I still 


look at his testimony in critical terms and 


say, well, I’m not going to dismiss his 


comments. 


MR. HINNEFELD: Ma’am, you wanted to say 


something, right? 


MS. BALDRIDGE: Yes, Mark can speculate on 


what he thinks. But when you read some of the 


other documents, when the Atomic Energy 


Commission comes in and says you’ve got to 


clean this up, and they’re response in writing 


is tell them what they want to hear, and then 


they go on to say, you know, the situation’s 


actually getting worse than, instead of 


better. That tells me that it’s questionable 


whether their concern was to rectify the 


situation or just get the Atomic Energy 


Commission off their back. 


MR. ROLFES: Once again, it’s a matter of 


interpretation on how you read it. For 


example, if this were in fact in a uranium 


area, however, these results would not be of 


significance to us because we once again would 


be relying on the bioassay data that we have 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

250 

for the individual. We wouldn’t be using the 


air monitoring data that was recorded to 


assign intakes for those employees involved. 


We would be using their bioassay data which is 


the most representative approach of actual 


worker exposure. It’s the most precise, I 


guess, approach for estimating a worker’s true 


exposure. 


 DR. WADE: I mean, you can argue forever 


about the motivation, but it should become 


unimportant. The key question is was data 


destroyed or --


MR. GRIFFON: Or falsified. 


 DR. WADE: -- falsified, destroyed, in some 


way corrupted. That’s what needs to be 

investigated. 

MR. GRIFFON: And I would say to that end if 

we have raw data to compare against these 


files you have, that’s one way to get at that 


question. Do we have logbooks from this 


individual or whatever. 


MR. CHEW: (Inaudible). 


MR. GRIFFON: Do you even have those 


available? 


MR. ROLFES: I haven’t seen any logbooks. I 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

251 

know I’ve seen some of the raw data reported. 


Most of the information that I’ve had 


available to me would be the electronic 


versions after they’ve been scanned. I know 


some of the data capture team members have, 


that have scanned the actual data. I can ask 


someone in ORAU to see if we have come across 


any logbooks. 


MR. GRIFFON: It looks like there’s Health 


and Safety or Health Physics reports anyway, 


monthly or quarterly. I’ve seen those 


referenced haven’t I? Health Physics reports? 


So that may have some information also. 


DR. ZIEMER: I’d like to ask. Hans, did you 


get the impression from this gentleman that 


that was the sort of common practice versus 


maybe a single event? He worked 17 years. 


DR. BEHLING: Yes. 


DR. ZIEMER: Was he suggesting that this was 


fairly standard practice on the site for him 


or for other workers? Does this stand out in 


his mind as --


DR. BEHLING: I guess, I didn’t obviously 


interview this individual myself. It’s a 


sworn affidavit that is available, and I think 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

252 

I took select pages starting with page 100 of 


the report that are direct statements that he 


submitted and are notarized. And so you can 


kind of look at those and draw your own 


conclusions. But I think it is not something 


that was an isolated event. 


MS. BALDRIDGE: Well, the document was part 


of the evidence submitted in court in 1990. 


 MR. CLAWSON: How many industrial hygienists 


did they have at Fernald? Does anybody know? 


I mean --


MR. ROLFES: Stu, might you know the answer 


to --


MR. HINNEFELD: Well, I was time dependent. 


I mean, from 1970 to 1980 there weren’t very 


many at all because there weren’t very many 


people working there. Before 1970, I think, 


they had a little healthier staff, but I 


couldn’t tell you. There were a couple in 


1980. 


MR. BEATTY: After ’80 there was only one 


RAD tech. I know that. 


MR. ELLIOTT: This individual, Mr. Rudy, was 


an industrial hygiene tech at the time. He 


actually came to NIOSH after he left Fernald. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

253 

He worked for me for awhile. I can tell you 


he was very ethical, responsible industrial 


hygienist. 


DR. BEHLING: And to answer Paul’s question, 


if you look, Paul, on page 101 of the report, 


item number seven, it’s a statement that 


should answer, at least in part, your question 


about how prevalent this issue might have 


been. And I’ll read it for everyone else who 


may not have the computer. 


Statement seven it says, “On several 


occasions during the term of my employment 


when I got air dust survey results that were 


above the MAC, I was told by my supervisors 


that it the results were an error, and I was 


told to go back and re-sample.” 


And then he goes on about this one 


instance where he was, went back multiple 


times before he decided to turn around and be 


downwind from the direction of the air flow, 


took his air sample because he knew from 


experience that simply rotating his body and 


the air sample 180 degrees would reduce the 


air concentration as measured by his air 


sampler. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

254 

So that’s as much as I know about 


whether or not this was a prevalent issue or a 


very episodic and inconsequential issue. 


That’s all I have is that statement. 


 MR. CLAWSON: This air data, I know that, 


and I guess it’s kind of odd for me for an 


industrial hygienist to be pulling these 


samples because we have RAD techs pull them. 


But we have to have a calibrated instrument to 


be able to pull these samples so that we know 


that we’ve got the total flow. Do we know 


what were being used? 


DR. BEHLING: He refers to it as a homemade 


device. Now to what extent that is a fair and 


accurate description is again open to 


subjective interpretation. 


MR. HINNEFELD: Most of the devices must 


have had a flow rate indicator on it because 


most of the samples should have a flow rate 


recording. So it must have had some sort of 


anemometer or some sort of flow rate 


indicator. If you want to talk about the 


calibration of the anemometer in the ‘50s and 


‘60s, I’ll bet you’re not going to find any 


kind of calibration record for an anemometer 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

255 

in the ‘50s and ‘60s. 


DR. MAKHIJANI: Dr. Ziemer brought up the 


document destruction thing, and that reminded 


me that thorium documents were destroyed at 


Fernald if I’m remembering correctly in the 


early ‘70s. Do you have any idea --


MR. RICH: Process data. 


DR. MAKHIJANI: Process data? 


MR. RICH: Not air sampling. 


DR. MAKHIJANI: How do you know that? 


MR. RICH: Well, we have some. We don’t 


have it all. 


DR. MAKHIJANI: I mean, do we have some idea 


what was destroyed and what kind of production 


and process information might have been 


destroyed and what was retained? 


MR. RICH: Well, the major reconstruction 


process for the thorium operations was 


primarily in the process area. We have a team 


put together to reconstruct what had been 


lost. The equipment, the process equipment 


had been removed and that was gone plus the 


fact that during the declassification period 


some of the process data had been, they were 


unable to recover data in any other 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

256 

repository. So they put the team together to 


reconstruct what they primarily processed. 


DR. MAKHIJANI: Is there a record of that 


reconstruction? 


MR. RICH: Yes, yes. 


DR. MAKHIJANI: Can we have that? 


MR. RICH: You have it. 


DR. MAKHIJANI: We have it? 


MR. RICH: Yes. It’s, that processing’s 


described in -- I’m trying to remember the 


author right now. I’ll think of it. I’ll 


think of it in just a minute. 


MR. GRIFFON: When you say process data was 


destroyed, was this table you handed out 


earlier based on reconstructed thorium 


information or was it --


MR. MORRIS: I’d say new interviews. 


MR. GRIFFON: New interviews, okay. 


MR. RICH: Yeah, and I guess that is Dolan 


and Hill. 


DR. MAKHIJANI: I have looked at Dolan and 


Hill. 


MR. RICH: And Dolan and Hill, part of that 


is described, part of this process and part of 


the disposal was described in that report. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

257 

DR. MAKHIJANI: I have looked at Dolan and 


Hill. I saw that that was in your TBD --


MR. RICH: And there may be another -- if I 


come across the, there’s at least a couple of 


references that talk about this -- I’ll --


DR. MAKHIJANI: But Dolan and Hill was based 


on interviews that were at least not available 


to us. I remember I asked because it said we 


reconstructed this from interviews, and here, 


there’s going to be a kind of an issue as to ­

-


MR. RICH: They describe the interview 


process, but I’ve not seen a formal record of 


the interviews. They probably did not 


document it that way. 


DR. MAKHIJANI: There was a document 


destruction in the ‘70s, and then Dolan and 


Hill -- I’m just trying to figure out what 


happened here. Dolan and Hill did some 


interviews and put something together about 


production --


MR. RICH: It was more than a set of 


interviews. They put together a team of 


professional engineers that had been there at 


the plant during the operation, and they 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

258 

collectively, as a reconstruction team, put 


together, based on best recollection and what 


information that they could assemble which 


included both the effluent data and the 


process descriptions. 


DR. MAKHIJANI: Did that team produce a 


discrete report or was it just, did they just 


talk to, Dolan and Hill and the -- because 


Dolan and Hill had hardly any underlying 


information about how the thorium data, where 


the thorium data came from. It just has the 


data. 


MR. RICH: Well, it’s the results of the 


committee’s work were reported in Dolan and 


Hill. 


DR. MAKHIJANI: The committee itself didn’t 


file like a report that was then -- because 


Dolan and Hill covered everything, right? It 


covered uranium. 


MR. RICH: Right. 


DR. MAKHIJANI: It covered thorium. It 


covered, and only a small part of Dolan and 


Hill is devoted to thorium; whereas, the 


destruction of the records is specific to 


thorium. So obviously some considerable 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

259 

effort must have gone into that small piece of 


Dolan and Hill which relates to thorium. And 


I’m not at all confident that Dolan and Hill 


captured the thorium operation. But there 


must have been some report from this committee 


to Dolan and Hill who had a much bigger job. 


MR. HINNEFELD: I remember Dolan, and I 


remember Hill. But I don’t remember this 


activity so I’m afraid I can’t answer that. 


MR. GRIFFON: Is this committee listed in 


the references in Dolan and Hill? 


DR. MAKHIJANI: No, no, there’s no record. 


I was not able to find any underlying -- I may 


be wrong, but this is just my own, our little, 


small team’s review. But we were not able to 


find any underlying information, and I 


remember asking about it and came up with 


nothing. 


MR. HINNEFELD: Is the record destruction 


really strictly just thorium though? I mean, 


Fernald had a records retention. They 


followed the Department of Energy’s records 


retention schedule pretty carefully and threw 


things away when they go to their lifetime, 


and not every site did that. But Fernald, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

260 

from my recollection, was pretty careful about 


throwing things away when the DOE said they 


could. And so I would think that there would 


be a large category of records that were 


dispositioned in accordance with those what 


were called the retention, retention schedules 


is what they were called. 


MR. RICH: They just mentioned the thorium 


discussion because evidently it was complete 


enough that they had to put together a 


committee to actually reconstruct, to answer 


questions that came as a result of some other 


issues. 


MR. HINNEFELD: Okay, because I don’t 


remember that task to do that reconstruct 


(inaudible) the thorium. Records were 


destroyed routinely when they have reached the 


end of their retention time. Now, none of the 


records related to exposure should have been 


in that. They had a much longer retention 


time. So they should not have been destroyed. 


DR. MAKHIJANI: And maybe you’re right. I 


mean, I don’t know. The only thing I’ve come 


across is a reference to the destruction of 


thorium records. And Bryce may be right in 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

261 

that those have become relevant because --


MR. RICH: That would not have been 


destroyed. There was no authorization to 


destroy a bioassay record or anything related 


to dose itself. Now, that did not include 


field operating data like air sampling. So 


frankly, I don’t know if there was some, 


because my impression is that we don’t have 


all of the air sampling data yet. We have a 


significant body, but I’m not satisfied that 


we have everything that was taken. 


DR. MAKHIJANI: You have done new interviews 


though after Dolan and Hill. Now you’re going 


through that. 


MR. GRIFFON: So this matrix including, I 


think you have some numbers on the one that 


you presented, but --


MR. MORRIS: To be clear about where I got 


that. There are a lot of documents and some 


that were cited in the SEC petition that had 


production data in them. When those were 


available, I picked those up. Sometimes I had 


three different documents that had three 


different numbers in them, and I just had to 


choose. That’s available in the annotation 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

262 

that you’ll see eventually on there. And then 


we did do additional interviews that clarified 


a lot of the uncertainty about this. 


MR. GRIFFON: Go back to the matrix. 


MOBILE IN VIVO RADIATION MONITORING LAB
 

DR. BEHLING: The next topic that we want to 


discuss is on page 104, and it deals with the 


mobile in vivo radiation monitoring 


laboratory. And I have just a couple comments 


that are not, and I’ll say it up front, this 


is not considered a finding by SC&A, but I did 


have some questions about the lung counting 


systems, and it’s been something that’s 


bothered me from the days where I reviewed 


some of the Oak Ridge team, and that is the 


use of a lung counter that’s defined by a 


nine-inch- by four-inch-thick sodium iodide 


crystal. 


And, of course, I would consider that 


a very unsuitable device for doing lung 


counting. It’s great for doing the whole body 


counting if you want to look at CCM of Cobalt60. But certainly not very suitable for 


counting 60 or 93 keV photons from uranium 


which was obviously the central reason for 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

263 

introducing the mobile counting system there. 


And so having said that my first --


and I show a couple things that look at the 


spectrum and you realize you get a lot of 


backscattering at the left-hand side which 


reduces your signal-to-noise ratio and limits 


your sensitivity by orders of magnitude. In 


fact, many of the other lung counters that 


have been in use whether it’s at Hanford or 


(inaudible), they used, instead of four inch, 


they used four millimeters. And, of course, 


that would be one-twenty-fifth the thickness, 


and that would be the most desirable detection 


system for doing chest counting. And so I 


couldn’t quite understand why --


MR. MORRIS: That might be for plutonium 


typically where you’re looking at much lower 


energies than that, 60 keV. 


DR. BEHLING: But here they also looked at 


the Thorium-234 daughter as a surrogate for 


Uranium-238. And that has 63, and it’s 93 


keV, so --


MR. RICH: But that’s Thorium-234, plus it’s 


shown as 235. And 235 had got a --


DR. BEHLING: Hundred and eighty-six keV. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

264 

But that, too, is also a problem 


because it coincides at the 180 backscatter 


photon that you get from high energy photons. 


So it, too, has a problem even though it’s 


much higher in energy, it coincides with the 


180 backscatter from cesium and cobalt which 


fall in between 180 to 210 keV backscatter. 


MR. RICH: As you know, if you get cesium 


and cobalt, it’s a problem. 


DR. BEHLING: It’s a very big problem. 


MR. RICH: But when you don’t have cesium 


and cobalt, why, you can do a better job. The 


MBL is a little bit higher. That’s true. 


DR. BEHLING: And I guess I just couldn’t 


understand why they would select that 


particular system both for Oak Ridge as well 


as for Fernald as a mobile unit. 


MR. RICH: It’s your only game in town. 


MR. MORRIS: Probably. 


DR. BEHLING: And the other thing that I 


wanted to, brought it up here, when you look 


at Thorium-234 as a surrogate for 238, you 


also have to make some assumptions about 234 


because in most instances, that’s the 


radionuclide you’re going to assign the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

265 

highest PCF to. And therefore, it is that 


particular radionuclide that you’re more 


interested in. 


And, of course, that dominates when 


you start to have an enrichment or at the end 


if you have a highly enriched, it’s U-234 that 


dominates the activity. And where were the 


assumptions here regarding, since you didn’t 


look for anything that involved 234, but you 


used 235 which gives you some indication if 


you’re dealing with enrichment, admittedly. 


But it’s a fairly complicated process 


by which you say, okay, I have Thorium-234, 


and that has a very weak photon energy and a 


very low yield, and I have a fairly high yield 


in 186 keV photons from U-235. Now in order 


for you to understand what’s in there in terms 


of 234, you would have to then weigh those two 


balanced Thorium-234 against the Uranium-235 


photons and get some estimate as to how much 


234 is in there. 


MR. RICH: Some of these are not done in a 


vacuum. You’ve got to know something about 


the material that you have been exposed do. 


So you start with some field data and know a 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

266 

little bit about the source of exposure, and 


then you’re able to do it. 


DR. BEHLING: And it brings us back to the 


issue at Fernald where you had everything from 


depleted uranium up to seven percent and 


possibly even higher. And so the question is 


how do we account for 234. 


MR. RICH: But they’re generally no higher 


energy emitters in the (inaudible) except for 


Potassium --


DR. BEHLING: Yeah, and cesium. 


MR. RICH: -- a little bit of Cesium-137. 


MR. ROLFES: The bottom line is that because 


we have urine bioassay data, that’s going to 


be our first, most important piece of 


information or data within the Health Physics 


hierarchy for reconstructing an internal dose 


for a person. 


MR. RICH: The same thing’s true of thorium. 


You have to know a little bit about the 


relative equilibrium. 


DR. BEHLING: We’re going to get into that. 


MR. RICH: Oh, you are. Maybe we solved the 


problem here now. 


DR. BEHLING: There are some serious 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

267 

problems here, and I guess I’m going back just 


as an opening statement here and said this is 


not a finding. It’s just a comment I want to 


make here when I talked about the issue of the 


design system that is not very suitable for 


low energy photon detection based on the 


thickness of the sodium iodide crystal. 


But the second issue I raised was 


operator experience. And in one of the memo I 


remember reading, and I looked at these 


carefully. The memo stated many lung counts 


that were made for screening purposes are made 


under circumstances which require the 


interpretation of the count results by someone 


familiar with the vagaries of in vivo 


measurements. While all count data are 


contained in the employee’s file, not all 


results are useful as an expression of the 


true lung burden. 


And it’s when I gathered the initial 


year during which the mobile unit was 


introduced, it was operated by personnel from 


the Oak Ridge. 


MR. RICH: Yes. 


DR. BEHLING: After that it was turned over 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

268 

to the people and say you’re on your own now. 


The question is, and I think this is where 


this statement alludes to, is perhaps the inhouse people who at that time took over the 


operation of the mobile unit were, in fact, 


properly schooled in operating this systems as 


well as in interpreting the data. 


MR. RICH: I think, Stu, you may be able to 


comment more on that, but my impression is 


that that they were, the responsibility for 


the training was Oak Ridge, and my impression 


is at least that they were adequately trained. 


MR. HINNEFELD: Well, I’m trying to recall. 


Never operated it myself. People who operated 


it were trained. They relied on Oak Ridge for 


the training and the knowledge for, you know, 


how to deal with the science. You talked 


about certain exams being called screening 


exams. 


As I recall, any exam where the person 


had gone to work that day and then come out 


and had got a count while he had already been 


in the process area was considered screening, 


meaning given the contamination environment at 


Fernald, and it was a contaminated 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

269 

environment, there’s a decent chance that a 


guy could be contaminated when he got in the 


chamber from his work that day. And so a 


record count either had to be like a first day 


back after a weekend off or maybe first thing 


in the morning, when you came in in the 


morning after getting back. 


That was kind of like some, I think 


the screening count was one like that where 


you didn’t worry so much about the subject’s 


pedigree. It’s what he’d been doing that day 


before he got in the chamber. That’s my 


recollection. Now, this is more than 20 years 


ago I’m talking about. I could be wrong on 


that. 


MR. RICH: But the records indicate also 


they didn’t do monitoring for, which was 


incident driven. In other words if they’re 


involved in something, they didn’t count on 


Monday. 


MR. HINNEFELD: Yeah, if the counter 


happened to be there, and there was an 


incident, they’d bring people over to the 


counter, sure. 


MR. RICH: And that’s another point. This 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

270 

is, was a mobile van that was not there all of 


the time. It came frequently, at least once a 


month. 


MR. HINNEFELD: Usually, I think it came 


twice a year normally, and they would count as 


many people as they could essentially. 


MR. ROLFES: The highest exposed personnel 


like the chemical operators, et cetera, were 


generally moved to the top of the list or 


those people that had been involved in an 


incident --


MR. HINNEFELD: Had a burden, people who had 


an identified lung burden in the last count, 


they were normally counted every visit. And 


so, yeah, those were kind of the selection 


criteria on who got counted. 


MR. RICH: I think a little bit later on the 


frequency was greater than that, but I --


MR. HINNEFELD: Well, maybe, I don’t 


remember for sure how often it showed up. 


MR. RICH: It served a number of facilities, 


but I think they were maybe down to once a 


month or so. 


MR. HINNEFELD: Well, you had it for a 


certain amount of -- when it came, it didn’t 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

271 

just come for a week and leave. I mean, it 


was there for weeks, and the counting was done 


for weeks, and then it left. And I was 


thinking it came at roughly six-month 


intervals. It wasn’t exactly six months, but 


I was thinking roughly six-month intervals at 


least when I started. 


But in terms of the operators’ ability 


to use the system, I believe they knew how to 


use the system because they were taught by Y12 staff, this is how you use the system and 


this is what you do. But the system design 


and really understanding the system, I think, 


was mainly the Y-12 folks who really 


understood the system other than a few things 


that the operators knew locally and going so 


far as a front-to-back ratio because there 


were detectors above and below the counting 


table. 


And the front-to-back ratio if a 


person has a lung burden, should be close to 


some value, should be actually a little higher 


I think in the back. The back count, I think, 


should be a little higher than the front count 


if it’s a true lung burden. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

272 

If a person comes in with 


contamination more likely on the front of 


their body, and so you can have an 


extraordinarily high front-to-back ratio which 


is an indication this is probably a 


contaminated person who was out in the process 


area. We need to get him showered and get a 


record count over here to see if, in fact, 


that was a burden that we measured or just 


contamination on his skin. 


So were things like that. I mean, 


that’s some of the vagaries of interpretation 


that they were talking about. But other than 


that I don’t think that Fernald tried to 


interpret things very much because the whole 


system is a little bit of a black box that 


Fernald operated. You know, you put in the 


number, and it counted the specific regions of 


interest, and it calculated what was called 


the expectation value. How many counts they 


expected to have in that region because of the 


K-40 peak and the person’s size. And then the 


difference was what the result came out. 


And so it pretty much was black box, 


and even knowing what the region of interest 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

273 

was or what they called the prediction 


equation was, how did you predict those count, 


even that was, the Fernald operators by my 


recollection weren’t too well versed in that. 


That was all provided by Y-12, and it was a 


sort of a black box sort of thing. That’s my 


recollection. 


DR. ZIEMER: Well, I think you’re right. It 


clearly isn’t an optimum system, but this is 


true of many whole body counting systems which 


were some of the, like all around the country. 


And for most systems it’s the optimum 


counting, it goes with the sample squared 


count over background. The background clearly 


is too big here with the big crystal. And you 


compensate for that by longer counts and then 


the front-back business. Also, to do this 


right you have to have a background for each 


person. The K-40 peak is different for every 


person. It’s based on your muscle mass. Some 


people have big K-40 peaks. And, of course, 


this is probably a cesium peak in here during 


those years, right? 


DR. BEHLING: Yeah, you had, obviously, a 


fallout that would even for a non-occupational 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

274 

person be --


DR. ZIEMER: Yeah, and the cesium 


distributes like potassium in the body so that 


also is a very personal one variable person-


to-person. But if you have the person’s 


background and count long enough, you could 


optimize it even though it’s not the best 


system. 


The problem is your low limit of 


detection is the problem. What you can really 


see becomes more and more difficult if you 


have this high background that you’re 


fighting. But I’ve seen counters with 


terrific backgrounds that if you count long 


enough, you can get pretty good results. 


DR. BEHLING: Yeah, as I said --


DR. ZIEMER: But you have to have, you’ve 


got to take care of the background, the 


geometry and people have to know how to strip, 


you’re doing a spectrum strip. 


MR. RICH: And Hans, (inaudible) came on a 


little bit lower, and then the jelly detectors 


came after that. This was the front end of 


the camel. Whole body counting, the large 


crystals were good for whole body. It was 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

275 

used as primarily lung counter in this 


situation, and it functioned with an MDL that 


was not quite as good as we can do today. 


MR. CHEW: Hans, is there a real question? 


DR. BEHLING: No, no, again, it was really 


an issue that says be careful of (inaudible) 


are the low limits of detection because it may 


be higher than you thing it is, and it should 


be. 


MR. RICH: And that’s right, plus the fact 


that it represented the state-of-the-art at 


that time as provided by Oak Ridge. 


DR. BEHLING: The next finding is also on 


page, actually, it’s 106 on my copy, the use 


of surrogate daughter products and unsupported 


assumptions for thorium exposures. And that 


is basically an issue here that I think we’ve 


just alluded to with Bryce. And that is what 


do we do with thorium? We have Thorium-232, 


and we have Thorium-228, and depending on 


where you are in the process you can make 


assumptions regarding the relationship between 


the two. If you start out with virgin ore, 


yes, you can assume that the two are in 


equilibrium along with all their daughter 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

276 

products. That’s not an unreasonable 


assumption. But the minute you extract them 


chemically, you may still have at times zero 


in equilibrium condition, but in due time 


you’re going to have decay of Thorium-228. It 


has a half-life of 1.9 years so that in less 


than two years you reduce it by radioactive 


decay by a factor of two. At the same time 


you have an in-growth of Radium-228 which is 


the daughter product of 232 that has a 6.7 


year half-life, and it also now produces 


Actinium-228 which is your surrogate for 232. 


Now the question is --


MR. RICH: That’s a 5.7 your half-life, 


building slower, and then with the Thorium228, with the chain down to again maybe of 


Lead-212. 


DR. BEHLING: Yes, I was. And here’s where 


you have a problem in looking at the thorium. 


And later on the discussion is, well, we use 


either Actinium-228 or Lead-212. The question 


is which one did you use and what assumptions 


applied, and how old do you know the material 


was so that you can make a correction. 


Because at the worst, if you looked at -- you 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

277 

always know you’re going to see Lead-212 


because you’re always going to see as a 


minimum 35 percent. The relationship between 


232 and 228 bottoms out in about seven years 


or so when you get about 35 percent --


MR. RICH: Forty-seven percent. 


DR. BEHLING: Whatever it is. 


MR. RICH: Yeah, you look at Lead-212 which 


gives you a direct, and then you’ve got to 


assume that the thorium stays. And then you 


can get a pretty good estimate of the Thorium228, but you’re only halfway there then 


because of the fact you’ve got to know the 


history of the material at the last process. 


So you apply a factor of 1.4 or 1.2, 


depending on the degree of equilibrium between 


Thorium-228 and 232. Well, they made a 


determined effort at Fernald to track and have 


a good feeling for the separation. And that 


was used in the determination of the -228 and 


Thorium-232. And then the mass quantities 


reported were Thorium-232. 


DR. BEHLING: It’s very critical because 


according to the statement here, and it’s 


taken out directly here from Section 6.2 of 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

278 

the TBD. It says, “Thorium-232 and 228 


activities were determined based on 


equilibrium assumptions. The detect was most 


likely Actinium-228, Beryllium-232, but Lead212 may have been used for the assessment of 


both thorium isotopes. 


MR. RICH: We used calibration. 


MR. MORRIS: It was a calibrated system. 


DR. BEHLING: Because if you allow yourself 


to limit yourself to Lead-212, you could be at 


the bottom of the curve, and that means you’re 


only measuring 43 percent present of 228 


versus 232, which means you would 


underestimate --


MR. RICH: That’s just a calibration of the 


energy from, so that you’d know how much Lead212 and how that comes out on your spectrum. 


MR. MORRIS: Yeah, you need a stable 


calibration; it doesn’t change by month. 


MR. RICH: Then at that point, then it’s a ­

-


DR. BEHLING: But you would need both to 


assess a person. Suppose a person was 


counted, and he, at this point, had been 


exposed to purified thorium. You know very 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

279 

well at times zero the two should be in 


equilibrium. But unfortunately, Actinium-228 


is there, so now you’re stuck with 212 as your 


sole source, and you would have to now make an 


assumption. What is my Thorium-232 worth? 


MR. RICH: If you get a very freshly 


separated one you’re dead. 


DR. BEHLING: You’re dead because you have 


no way of knowing --


MR. RICH: You have no daughter product. 


DR. BEHLING: That’s right. 


MR. RICH: You don’t have any Lead-212. 


DR. BEHLING: Well, you have Lead-212 


because it’s only a matter of days before the 


grows in. 


MR. RICH: That’d be in a couple weeks. 


DR. BEHLING: Couple weeks. I mean, we’re 


not talking, when I say times zero, you could 


take a few months. 


MR. RICH: You might not be completely 


there. 


DR. BEHLING: But the truth is for a fairly 


long period of time your only indication of 


thorium present is Lead-212. 


MR. RICH: And so admittedly it is, and it 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

280 

requires information related to the process 


history of the material we’re dealing with. 


MR. CHEW: It’s so fresh the daughters could 


not contribute to the exposure. 


DR. BEHLING: No, no, we’re not worried 


about the daughter. We’re worried about the 


thorium. 


MR. RICH: Determining the mass quantity of 


thorium. 


DR. BEHLING: No, I just had that as open-


ended question because you have this wide 


variation in terms of what can be there, and 


based on what it is, whether it 212 or 


Actinium-228 that you’re using as a means of 


assessing body burden. 


MR. RICH: The process used at Fernald was 


developed at Y-12 because of the fact they 


were using large quantities of thorium there 


also. And the mobile laboratory was developed 


there and calibrated there and taken to 


Fernald. So it’s an Oak Ridge technology that 


was used at Fernald. 


DR. BEHLING: I guess the next one is 


Finding 4.4-3 --


MR. GRIFFON: Before we leave dash-two, what 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

281 

is there any action on this or, I mean, at 


what point do you rely on that data, your dose 


reconstruction process? 


DR. MAKHIJANI: There are data you said on 


how old the thorium is and so on and you 


collected it? 


MR. GRIFFON: Yeah, that’s the question I 


had is do you have enough to determine the --


MR. RICH: That’s not recorded in the 


calibration, and so it is part of the counting 


and the correction parameters that went into 


the determination. All we have is the data 


associated with the count. 


DR. ZIEMER: What does the dose 


reconstructor do at that point though? 


MR. RICH: He reports it in milligrams and 


records it. Or in later years it was recorded 


in activity units of Lead-212 and sometimes 


Actinium-228 which is kind of difficult to do 


well unless you’ve got a long-term source. 


DR. MAKHIJANI: Well then, how do you 


translate it back? 


DR. ZIEMER: Yeah, what does the dose 


reconstructor do with that? 


MR. RICH: Based on the age of the material, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

282 

there are correction factors to apply to the 


activity --


DR. ZIEMER: Does he know that? Does he 


know the age? 


MR. RICH: Well, you have to --


DR. ZIEMER: Or based on the process he 


assumes a certain age. 


MR. RICH: Yes, that has to be so. 


MR. ROLFES: I believe our dose 


reconstruction approach will rely on the air 


monitoring data that we have primarily that 


would be the first order, the piece of 


information. And then if we have specific 


information in a claimant’s file that 


indicates that their global in vivo results 


for thorium were greater than our air 


monitoring data, I think that that would then 


be our approach --


MR. RICH: However, in no way do we want to 


imply that the process is efficient. It was a 


standard accepted process. The fact that the 


data, the lung counting data, is fundamentally 


low, it demonstrates for the most part just a 


few individual that have significant body 


burdens. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

283 

MR. MORRIS: Lung burdens. 


MR. RICH: Lung burdens. And as a 


consequence then in the use of air sampling 


data to calculate intake, that’s much higher, 


much higher than would be indicated by the 


lung counting data which, based on where it 


came from and the procedures that are there, 


it’s an acceptable process by then current 


standards. 


MR. MORRIS: Specifically to the calibration 


and assumptions of the calibration, I’ve got a 


note from Tom LaBone last week regarding how 


he has modeled the in vivo coworker data using 


IMBA. He confirms that that was 100 percent 


equilibrium assumed for calibration purposes, 


and which would, and then for the modeling he 


assumes, I think, 42 percent value of the 


activity ratios if it dips down at four and a 


half years post separation. And that results 


in --


MR. RICH: I think the 1.42 is 70 percent. 


Seventy percent over, one over 70 percent of 


1.42 --


MR. MORRIS: So we have a 1.42 adjustment 


factor that’s --

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

284 

MR. RICH: And that accounts for about a two 


year after, and it’s conservative by a factor 


of 0.42 in addition to equilibrium. 


MR. GRIFFON: And this is documented where 


or we’re still waiting for, I mean, is this in 


your TBD yet or it’s coming? 


MR. MORRIS: This is one of those coworker 


studies that’s in progress right now. 


MR. CHEW: Thorium, it’s a thorium coworker 


study. 


MR. GRIFFON: And did I understand, Mark, 


correct that you’re saying you’re only going 


to use the in vivo coworker model if it 


results in a higher dose than the air sampling 


for thorium or -- I’d like to know the 


decision logic, too, on this. I think it’s 


important. 


MR. RICH: It’s going to default high. 


MR. GRIFFON: Default high. 


MR. MORRIS: And I think what we’ll really 


be using our in vivo data for is just to prove 


that our default values are bounding. 


DR. MAKHIJANI: So you’re using air 


monitoring data throughout the period even 


after 1968 as the primary dose reconstruction 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

285 

data? 


MR. RICH: Yeah, basically because we have a 


significant database of air sampling data --


and check me if I’m wrong -- it’s a lognormal 


distribution, and we’re defaulting to the 95 


percent. 


MR. MORRIS: We are going to allow the dose 


reconstructor to interpret. We will provide 


intake rates based on 95th percentile, 50th , 


and 84th percentile. 


MR. RICH: And assure ourselves that has not 


picked up anything higher than that. And as a 


consequence that data is there also so it’s 


defaulting high all the way from, 


significantly high I might add. 


 MR. MORRIS: I mean, it’s not high. 


DR. MAKHIJANI: Sorry, which is default? 


MR. RICH: The air sampling data, the 


intakes, by a large amount. Mutty’s not here. 


 MR. SHARFI: They should have streaming 


chest counts. 


MR. RICH: Primarily because there’s some 


uncertainty involved in thorium. 


DR. ZIEMER: If they were that high even a 


nine-by-four crystal would be a (inaudible). 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

286 

MR. GRIFFON: And do we approach the 


question of plausibility. That’s another 


factor you have here, I guess. If they were 


so high predicted, are these just real high 


numbers or are they actually plausible 


exposures? It’s an SEC question. 


MR. ROLFES: They’re based on monitoring 

data. 

 MR. SHARFI: They’re a bounding scenario and 

we’re taking the upper end. You’re giving 


them every day for an entire year when you’re 


looking at the upper end. They were sampled 


for probably a short period of time. You’re 


probably going to end up over assigning the 


overall intake over the course of a year. 


MR. RICH: And this adds to the fact that 


the operation for thorium, and because of the 


limited amount of thorium handled, less than a 


metric ton per day, this is going to bias and 


default high because of the, we’re assuming, 


full-time operation. 


 MR. SHARFI: Three sixty-five. 


MR. RICH: And so all of it’s going to come 


out large doses. 


 MR. CHEW: I think Mark commented it’s so 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

287 

high it doesn’t make sense. 


MR. GRIFFON: Is this just a way to avoid 


the fact that you don’t really have enough 


information to calculate a good dose, you 


know? I mean, you’re just throwing a high 


number at the problem. 


MR. ROLFES: Sure, when we complete a dose 


reconstruction keep in mind when we’re 


assigning intakes to compensate people, say 


for example, if they have a positive uranium 


urinalysis result. Rather than reconstructing 


each individual acute intake, what NIOSH does, 


we can demonstrate pretty quickly that if a 


person has positive bioassay, rather then 


fitting each of those positive bioassay to 


separate, episodic events, we assume a chronic 


intake across the board. And that’s an 


accepted method that we’ve used to compensate 


people. So in my opinion I think that these 


exposures are plausible and of sufficient 


accuracy. 


MR. GRIFFON: I’m just throwing that out 


there for the work group to consider. We need 


to see that, the model, yes. 


 MR. SHARFI: Normally chest counts, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

288 

especially it’s in the soluble form. I don’t 


know if the body burden then becomes so 


outrageous that, the chest count, the chest 


burden would become so outrageous that way 


over predicting. The systemic organs would be 


using the air intakes and looking at the Type 


M which would be obviously more claimant 


favorable. And you’re probably now looking at 


a gross overestimate of what the chest burdens 


should have been. Like a lung cancer. You’d 


look either some Type S, and your intakes are 


very large, you should consider this acute 


build up of thorium inside the lung. 


 MR. CLAWSON: So we should be expecting to 


see a coworker data for thorium and for 


uranium? 


DR. BEHLING: Finding 4.4-3, it’s a question 


about what the selection criteria --


MR. GRIFFON: Hans, I’m sorry. Just to go 


back to 4.4-1, the same, are you using the 


uranium in vivo for anything or the same sort 


of scenario? I’ve got the sense that you 


always the urinalysis for uranium, right? 


MR. ROLFES: Yes. 


MR. GRIFFON: Do you ever use the in vivo or 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

289 

just maybe to check or --


MR. ROLFES: Exactly, basically if we assign 


one of those chronic intakes, this isn’t a 


typical dose reconstruction. It’s probably 


more towards a best estimate-type dose 


reconstruction. What we would do when we 


would assign an intake based on urinalysis 


data, we might check to make sure we’re in the 


correct ballpark by comparing that urinalysis 


data, or excuse me, the intakes estimated the 


urinalysis data to the actual lung burden 


observed just to give us confirmation that 


we’re in the correct ballpark of the worker. 


DR. ZIEMER: And if for some strange reason 


the lung burden gave a higher dose, then you 


would use that, right? Or would you? 


 MR. SHARFI: Are we talking about an 


individual case or --


DR. ZIEMER: Yeah, an individual case. 


 MR. SHARFI: I would assume you’d be looking 


to try to get both to agree whether it’s, I 


mean, you might end up becoming where you’re 


mixing intakes where you might be looking at 


an insoluble and a soluble form of intakes 


where you might use the chest counts to 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

290 

estimate your insoluble form, and the 


urinalysis to estimate your soluble form, very 


case specific. 


MR. GRIFFON: And for the coworker I don’t 


think they use it at all, right? 


MR. ROLFES: For -- I’m sorry. 


MR. GRIFFON: For coworker I don’t think 


you’re planning on using it at all, right? 


MR. ROLFES: The in vivo data, I don’t 


believe we are going to incorporate in vivo 


data into the uranium coworker model. I 


believe that’s strictly urinalysis. 


 MR. CLAWSON: Would we like to take a 


comfort break? People on the phone, we’ll be 


back in about 15 minutes. 


(Whereupon, the working group took a break 


from 3:08 p.m. until 3:23 p.m.) 


WORKER SELECTION CRITERIA AND INFREQUENT USE OF MIVRML
 

DR. BEHLING: Four-four-three. I guess 


there, there I was again questioning, and it 


goes back the early issues where we had these 


unexpected counts of uranium urine data for 


those four individuals. And here’s a 


situation where in the first statement that’s 


taken out of the TBD it says lung counting 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

291 

became available, it says, in ’68 in the form 


of a mobile unit and so forth. 


And then it goes on to say workers 


were counted on the schedule that’s based on 


internal exposure potential in their urine 


sampling. So there was obviously selection 


criteria by which people were selected. Not 


everyone was counted but the attempt was to 


count the people with the highest maximal 


exposure potential. I take it as that. 


But then I looked at a Health 


Protection Appraisal report that was issued in 


September of ’68 that had some second thoughts 


about it because it says in a recent in vivo 


monitoring of NLO employees utilizing the 


mobile unit, da-da-da-da-da, a serious 


question has been raised regarding the 


validity of the job-weighted air dust sampling 


approach long used by NLO since that data 


would not suggest lung exposure to these 


individuals at the in vivo indicated levels. 


In other words they observed a 


disconnect between air monitoring data for 


people who were obviously monitored for 


thorium who had the high potential and then 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

292 

found that perhaps that correlation did not 


exist. And the question is, is there a 


potential that indicates where people who were 


not counted but should have been counted. 


And I guess that’s the issue here, the 


selection right here. If we count everyone, 


then there’s no question. If we count a 


select one, the question is did we count the 


right people. And here’s a question that was 


raised where air monitoring data for thorium 


people did not match the expectations for in 


vivo measurements. 


And, obviously, it wouldn’t matter as 


you said towards uranium since you’re more or 


less relying on urine data as opposed to in 


vivo chest counting for uranium. But that was 


the issue here for this particular finding is 


that were the selection criteria necessarily 


good enough to say those who were not counted 


didn’t have a potential for thorium exposure 


just because they weren’t counted. 


MR. RICH: I guess all we can say is that 


their stated intent was to count the very high 


people, and based on the people in the 


database that we got from, they were operators 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

293 

and the like --


DR. BEHLING: Apparently a lot of people 


because in that same memo further on it stated 


it is therefore, noted with concern that only 


about half of those potentially subject to 


exposure have been monitored by the RDRML 


during this year. Meaning that obviously 50 


percent were not counted. And the question is 


were there people there that should have been 


counted but for reasons that they were not 


necessarily considered high-risk candidates 


were not counted. And so it’s an issue of 


data, complete data. 


MR. ROLFES: Also in the procedure that 


describes the people that were, in fact, 


monitored, if they weren’t monitored during 


one trip, I believe they were pumped up a 


little bit on the list for the next trip that 


was made by the mobile in vivo lab if they 


were in one of those higher exposure 


categories. This is just purely from memory, 


and I’d have to look back into the record to 


get the exact procedure for selection criteria 


for those workers. 


DR. BEHLING: But I would assume again here 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

294 

if a person was not necessarily monitored by 


in vivo measurements, the air monitoring data 


would still apply as a coworker model? 


MR. ROLFES: Yeah, exactly. 


DR. BEHLING: So as a minimum we use that as 


a default approach rather than saying you 


weren’t monitored; therefore, you were not 


necessarily at risk, and therefore, you could 


not --


MR. ROLFES: Correct, correct. 


DR. BEHLING: Yeah, the coworker model 


satisfies an awful lot of questions, open-


ended questions. 


MR. ROLFES: We certainly understand that. 


THORIUM LUNG COUNT DATA
 

DR. BEHLING: Finding 4.4-4, this is 


something that you’re probably going to 


answer, and I will withdraw this, and that is 


interpretation of Table 6-2 in the TBD that’s 


been introduced in this document on page 111. 


And I probably should have contacted some of 


you. I may have got an answer before I 


actually wrote this up. 


And that is the curious issue of 


converting thorium body burdens or chest 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

295 

burdens reported in milligram quantity as 


opposed to Lead-212 and Actinium-228 in 


activity values. And that transition, 


although, and what’s so strange here, if you 


look at that table that I incorporated, 6.2, 


and it’s introduced here in as Table 4.4-1 on 


page 111, you have as early as 1965, you have 


two counts that were recorded in terms of 


activity of Lead-212 and Actinium-228. 


And after there is a sprinkle of 


(inaudible) there, two in 1968 and a couple 


more and so forth. But for the most part the 


assessment for chest counting involving 


thorium that made use of Lead-212 or Actinium228 were very few. There’s only 15 for the 


time period of ’65 through ’77. On the other 


hand, if you look at the fourth column under 


thorium, you see in the year 1968 there were 


310 classified as thorium counts. 


Now, I wasn’t sure what that really 


represented. Why the conversion on your flip-


flop between activity values expressed in 


units of activity for Lead-212 and Actinium228 as opposed to milligram quantities of 


thorium? And I sort of interpreted this 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

296 

possibly I’m probably mistaken here. That 


they were not really looking at Thorium-232 


and 228, but they were possibly looking at 


Thorium-234. 


MR. RICH: It certainly wouldn’t be recorded 


in milligrams. 


DR. BEHLING: No, it wouldn’t be because it 


would be in extremely small quantities. 


MR. RICH: And if you’re in the claimant 


file, your claimant record, you’ll see 


frequently Thorium-212 and Actinium-228, but 


as a general rule in the initial records it 


was nearly all recorded as thorium milligrams. 


It should be interpreted as Thorium-232. 


DR. BEHLING: Well, this is what confused me 


because I did pull up a couple records, and I 


brought one here, and I crossed out the name 


of the individual. And up to the timeframe of 


1978, they were reported in terms of thorium 


milligrams, and your nanocuries for the 


daughter product. And I really was puzzled by 


what this really was. And I wasn’t sure 


whether the earlier years, up to 1977, most of 


those assessments did not really reflect the 


thorium that we were concerned about, mainly 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

297 

Thorium-232, 238. 


MR. RICH: No, it’s all 232. 


DR. BEHLING: It was all 232. And is there 


any indication as to how those numbers came to 


be. I mean, it seems strange that, as I said, 


throughout that time period if you look at 


that table, there are just a handful that were 


expressed in activity units for the two 


daughter products. And the rest, the bulk of 


them, were expressed as thorium milligram, and 


it just doesn’t seem --


MR. GRIFFON: Just the reporting convention 


at the time? 


MR. MORRIS: Well, I think it was a 


reporting convention switch. My recollection 


from looking at a whole set of air sample, I 


mean, lung counting results is that there were 


occasionally people who were sent to Argonne, 


Argonne National Laboratories, and they came 


back with different recording conventions. 


And that may explain why we had some in 


nanocuries in earlier years. But the really 


vast majority of workers counted at the in 


vivo mobile laboratory, and so I think what 


you see is just a gear shift from reporting 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

298 

from Argonne. 


DR. BEHLING: And I accept that. I just, I 


was puzzled, and I wrote it up because I felt, 


well, perhaps this is here where thorium was 


interpreted to mean something very different 


from what we thought it was. 


MR. RICH: As Bob indicated, the coworker 


data is -- Tom LaBone is making the conversion 


from Lead-212, Actinium --


DR. BEHLING: Activity values. 


MR. RICH: -- to compare with the --


DR. BEHLING: Right now it would be very 


troublesome to try to convert these. 


MR. MORRIS: Tom is doing that. 


MR. RICH: And for that reason it will all 


be consistent. 


DR. BEHLING: And I will obviously 


acknowledge that issue here because, as I 


said, we were just puzzling to me and was my 


interpretation that the real bioassay for 


Thorium-232 and 228 did not really commence 


until about ’78 when you see all of a sudden 


where we talked of near conversion although 


thereafter, they’re still milligram reported 


again. It’s now flip-flopped, and it’s hard 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

299 

for me to understand how you could have a crew 


of people operating the mobile unit, and then 


in some instances reporting it one way, and in 


another it’s another way, and the flip-


flopping. 


MR. GRIFFON: The flip-flop’s harder to 


understand because ANL wouldn’t have gone back 


to, you know. 


MR. RICH: Well, ANL didn’t count them all. 


They were counting them locally, but they just 


sent them down for the inner calibrations. 


DR. BEHLING: Well, as I say, I accept your 


explanation, and the assumption is that 


somebody will look at these data and reinterpret them and convert them into common 


units of activity. 


MR. MORRIS: It’s certainly happening now on 


the coworker study, and I think largely that 


is what they’re using this data for anyway. 


So that probably will suffice. 


DR. BEHLING: The next one is one that we 


touched upon this morning --


MR. GRIFFON: Hans, does this address the 


whole Finding 4.4-4? It talks also about 


correlation with air sampling data. Am I 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

300 

reading this wrong? At least in the matrix it 


says --


DR. BEHLING: Now, the air sampling data is 


really for thorium, and the uranium data is 


for the, you know, when people were selected 


under 4.4, the statement here is that they 


were selected based on urine data and air 


monitoring data. The urine data was used, it 


says, okay, you had high urine data. We’re 


going to assess you with chest burden for 


uranium. You had high air monitoring for 


thorium. We’ll assess you for a chest burden 


of thorium and so forth. And so, yes, as we 


started out by saying we don’t really care 


about the urine correlation because the 


primary source for dose reconstruction is 


always going to still be the urine data only 


as a back or up perhaps as a confirmatory way 


to assess the urine data will mobile in vivo 


data be used. But it’s not really the primary 


data. 


MR. GRIFFON: No, I understand that, but you 


were talking about the data discrepancy in the 


in vivo counts, but you didn’t really talk 


back to this question of the correlation of 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

301 

air data versus in vivo. Or maybe we already 


covered that. We discussed that before. I 


just wanted to make sure we didn’t miss 


anything. 


DR. MAKHIJANI: Well, I don’t know whether 


that remained as an action item after the --


MR. GRIFFON: Yeah, I think the action I 


have in the previous one was to, I think I had 


an action item. NIOSH was going to provide 


the in vivo coworker model. We’ve kind of got 


to wait and see that model. 


OTIB-0002
 

DR. BEHLING: Finding 4.4-5 on page 111, 


again, we question the application of OTIB0002 for efficiency reasons, and I think we 


discussed this morning. I’m still questioning 


whether or not the assignment of the 28 


radionuclide mix on the first day of 


employment necessarily will cover all bases 


for all workers, especially those who were 


long-term workers and for all cancers. 


I guess it would be at least some 


effort to assess, based on your new models and 


new assumptions regarding intake of uranium 


and thorium whether or not OTIB-0002 would, in 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

302 

fact, transcend any potential exposures 


assigned by those particular models. And I 


think it needs to be looked at. 


MR. ROLFES: Once again, we don’t really 


feel this is an SEC issue. OTIB-0002 was 


definitely used in the earlier days before we 


had detailed, site-specific information. And 


this was essentially an approach that NIOSH 


adopted to essentially provide the claimant a 


timely response and answer for their claim, 


basically yes or no as to whether the 


probability of causation would be greater or 


less than 50 percent. We do realize, now that 


we have additional data, this additional data 


can be used in lieu of OTIB-0002 so --


DR. BEHLING: I would assume that any person 


with a reasonable employment period but had 


cancers involving things such as lung cancers, 


lymphomas, bone cancers, liver cancers would 


not have been assigned OTIB-0002 as a way of, 


I mean, you must have had some screening 


methods for saying this should never be 


applied to certain types of cancers. 


MR. ROLFES: And typically for those cancers 


that you mentioned, those are typically organs 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

303 

that tend to concentrate radioactive 


materials. And essentially, because materials 


are deposited within those organs, they 


receive more dose. And simply, you know, to 


complete it, the other side of the efficiency 


method that if we have an individual with a 


couple of positive bioassays, we can do a 


simple underestimate and compensate that 


person for a lung cancer based on --


DR. BEHLING: My concern was more towards a 


person who may have had a radiogenic cancer 


that’s associated with uranium and thorium, 


but may have been a non-rad worker you may 


say, hey, we’re going to be generous to this 


guy or this person and give him the OTIB-0002 


treatment and see where we fall. And he may 


have had a cancer involving lymphoma or bone 


cancer or lung cancer or kidney or liver 


cancer. But on the basis of the fact that 


that person may not have been in his or her 


and the evidence that they were ever 


monitored, come to the conclusion that there 


was no exposure. Even though the cancer was 


the sort of cancer that might highly 


susceptible to an internal exposure to these 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

304 

two isotopes was dismissed and say, okay, 


we’ll just use OTIB-0002. I don’t know that 


that took --


 MR. SHARFI: On this lung cancer and stuff, 


OTIB-0002 is very specific that it is assigned 


to soluble intakes. And so stuff like lung 


cancer that are more accessible to insoluble 


materials would not, cannot even be used for 


OTIB-0002. And OTIB-0002 is specific on what 


organ it does apply to, and really more of the 


systemic system for more of the organs that 


are more radiogenically sensitive like a bone 


surface and like that. 


To assign OTIB-0002 would be to pay 


someone. And then I believe like the bone 


surface dose using OTIB-0002 is like 3,000 


rem. It’s so high you could never use it as 


an overestimate for a very sensitive organ. 


So it’s more limited to you radiogenic-


sensitive organs like the prostates and stuff 


like that that you can do these massively 


overestimates and not because radionuclides 


don’t compile inside this organ you can give 


them these large intakes and not see large 


doses. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

305 

Or the more sensitive like the liver 


and kidney and those organs, red bone marrow, 


bone surface, OTIB-0002 would, it would be 


almost impossible to use an overestimate 


approach because they’d end up resulting in a 


compensable which you can’t use an over-


efficiency method for a cancer. We’d have to 


then go back in actual claimant information 


and do either a better or a best estimate. 


MR. ROLFES: That’s another important point. 


In dose reconstructions this is a simple, it’s 


essentially a worse-case scenario that is 


applied. And, for example, for a prostate 


cancer there’s, it’s going to be very 


difficult to establish a probability causation 


of greater than 50 percent from internal dose 


for a prostate cancer. 


 MR. SHARFI: Tritium and stuff like that 


that has whole body --


MR. ROLFES: Sure, simply because of the 


biokinetic models. And even if, for example, 


if air monitoring data, I know we have a lot 


of discussion about air monitoring data. Even 


if the air monitoring data were orders of 


magnitude higher, still in most cases, certain 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

306 

organs are still not going to be, likely be 


compensated based on, based purely on 


biokinetic modeling. 


However, organs such as the lung or 


respiratory tract, those are obviously much 


more affected by insoluble materials than, for 


example, a systemic organ such as the 


prostate. So the claims that would be most 


affected by a change in air concentration 


would be those claims that we’re already 


compensating based on the bioassay data that 


we have. So we can debate the issue of the 


differences in observed air concentrations, 


but the net effect on claimants I don’t see as 


being very significant. 


Sandra. 


MS. BALDRIDGE: Because OTIB-0002 was used 


on my father’s claim we are locked into it 


until NIOSH gets their site profile revised. 


The Department of Labor will not send my 


father’s claim back with all the additional 


information that I’ve provided on thorium to 


even consider his exposure for three and a 


half years. We are locked into it. Now I 


think the law says plainly that dose 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

307 

reconstruction has to be based on exposure at 


such site where you’re exposed. The use of 


OTIB-0002 has been written into the regulation 


that has allowed NIOSH to use it. It is not a 


provision under the law because the law does 


not permit the substitution of data from one 


site to another site. 


MS. HOWELL: Actually, it does. The law has 


been interpreted by the Department to allow 


values from other sites. 


MS. BALDRIDGE: Interpreted. 


MS. HOWELL: It’s been interpreted. It’s up 


to the Department of Health and Human Services 


General Counsel’s Office and the Secretary 


himself to interpret how --


MS. BALDRIDGE: The data being allowed to be 


substituted for another site? 


MS. HOWELL: There’s a whole reason that we 


don’t that the Board is aware of. 


MS. BALDRIDGE: Yeah, but it should have 


been --


MR. GRIFFON: We’ve actually set up a work 


group, you might want to mention. 


MS. HOWELL: They are looking into science 


behind the uses of data from other sites, but 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

308 

currently, they’re allowed to do that. 


DR. ZIEMER: As a general principle whether 


in a specific case it’s appropriate might be 


subject to interpretation. As a general 


principle we can do that. 


MS. HOWELL: As a general policy in legal 


matters, you can use it. The question of --


DR. ZIEMER: It’s not an across the board 

thing. 

MS. HOWELL: -- the Board is the science and 

the question of whether or not it’s 


appropriate, and that’s why we set up the 


working group. 


DR. ZIEMER: We have a new working group 


that’s looking at that issue. 


MR. GRIFFON: But OTIB-0002 really isn’t 


even another site. It’s not data from another 


site so it’s --


MR. SHARFI: It’s based off like ten 


percent, I think, of the maximum --


MR. GRIFFON: It’s a high number. 


 MR. SHARFI: Yeah, they’ve basically taken a 


huge intake and said --


MS. BALDRIDGE: I thought it was based on 


(inaudible). 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

309

 MR. SHARFI: No, OTIB-0002, it’s based off 


the legal, I think the --


MR. GRIFFON: Maximum limits of the time 


period. 


 MR. SHARFI: Time period, yeah, and assume 


that they basically gave them, you know, I 


believe it’s ten percent of that for every 


single, 28 different radionuclides all at 


once, and by putting it in the first year you 


could maximize the dose that you’re assigned 


over time. 


MS. BADLDRIDGE: Then they’re addressing the 


time limitations that are included in OTIB0002 as well for applications outside the --


 MR. SHARFI: The dose reconstruction should, 


there are some time limitations that they need 


to, if they’re going use anything that 


obviously is outside I believe the 1970 OTIB0002 they need to defend why they think it’s 


still operable to that particular case. 


MR. GRIFFON: But I think that is an 


interesting point that you make, but in trying 


to appeal this, they’re bringing site-specific 


data, and their appeal is being rejected 


because it wasn’t based on site-specific data. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

310

 MR. SHARFI: That would be the person at the 


Department of Labor. I can’t speak for that 


side. 


DR. BEHLING: It does seem to have a 


conflict in the sense where efficiency is 


encouraged under the regulations, but at the 


same time if you look at the hierarchy of 


data, there’s no substitute to real data. And 


you’re actually then substituting new data for 


hypothetical data that’s not even applicable 


to any one site at all. 


 DR. WADE: And that’s a tension that we all 


live with under law. We need to be complete, 


and we need to be timely. 


MR. GRIFFON: I guess the one thing I said 


in this, at least in the matrix is that -- and 


I understand this from going through Rocky I 


think where we’re going to end up with this is 


that any changes that are made through this 


process, if they result in the modification of 


a DR approach that may affect any of these 


claims that have been made and reassess them. 


That doesn’t do much for your time of waiting, 


but it -- When a change is likely to -- so if 


the thorium model for a certain subset of 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

311 

workers ends up being very high, and it could 


affect OTIB-0002 rulings, then you would go 


back to those plans. 


MS. BALDRIDGE: [Name redacted] going to be 


94. 	You’re talking timely. 


MR. GRIFFON: I know. We do have the timely 


question. 


MS. BALDRIDGE: And this has been going on 


for seven years. 


PERSONNEL DOSIMETERS
 

DR. BEHLING: Let me go to the next section, 


Section 4.5 on page 113, and the first finding 


is stated as absence of performance 


standards/quality assurance for personnel 


dosimeters. It’s truly accepted that Fernald 


provided external dosimeters for its 


employees. But the question is to what extent 


can we look at the data and say that they were 


sufficiently accurate in assessing external 


exposures. 


And I took some of the statements out 


of the dosimetry assessment fact sheet that 


was dated September 11, 1981. And in there it 


basically says that all dosimeters values 


where in-house except for approximately the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

312 

first 12 months of operation. And so it was a 


dosimeter system that was processed by inhouse personnel. At the same time there are 


statements to the effect that there are no 


procedures available for how these dosimeters 


were processed. 


And statement number three, test 


dosimeters were not routinely processed, 


meaning that calibrations was bypassed. There 


was also an issue about accountability for 


dosimeters that were at times not properly 


stored. They were kept in people’s cars in 


heat weather and under environmental 


conditions that would obviously raise havoc 


with the response of these film dosimeters. 


And there were no specific training 


requirements for the badge technicians unlike 


today where we obviously have very, very 


strict criteria under various accreditation 


programs where people have to be qualified to 


operate the equipment and the processing of 


TLDs of dosimeters. None of that really 


existed. 


In fact, there was only one technician 


who had been assigned to this. And while he 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

313 

may have been qualified, but there’s no 


documentation to that effect. So the question 


is one of the absence of performance standards 


and quality assurance for personal dosimeters. 


And clearly by today’s standards we 


would obviously have reasons to be concerned 


about the qualifications of these people who 


essentially were people who learned on the job 


as opposed to having some form of documents 


that we provided some proof that they were 


qualified to do the job they were asked to do. 


Again, there’s not much we can do but accept 


that as a limitation in terms of accuracy for 


the dosimetry system. 


The next issue --


MR. GRIFFON: Do we have any --


DR. ZIEMER: Just a question that they were 


using the Oak Ridge system. Is that the 


understanding? 


DR. BEHLING: Yes. 


DR. ZIEMER: And did Oak Ridge process the 


badges or did --


MR. HINNEFELD: Fernald processed the 


badges. 


DR. ZIEMER: Fernald processed them. Using 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

314 

an Oak Ridge methodology or, I mean, you’re 


talking about developing film and reading --


MR. HINNEFELD: Developing film and reading 


with a densitometer. 


DR. ZIEMER: Did they calibrate with their 


own sources and so on? 


MR. HINNEFELD: Yeah, it’s in the report, 


you know, the continuation of the response to 


that questionnaire is that they shot 


calibration badges and read those and drew a 


densitometer curve using optimal density 


versus dose or generate a curve for each of 


the badges read. 


So as they developed a set, they would 


then, they would also at the same time they 


were developing the personnel badges, they 


would develop their standard values, the 


calibration values for that batch. So they 


had a calibration per batch, per development 


batch. And so those were then, you know, that 


was a calibration then for that batch. I 


mean, I’m just reading from the report. 


MR. ROLFES: As I was told in an interview 


by a former employee at Fernald was that the 


badges were calibrated to a slab of uranium 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

315 

metal, and the net result was that the dose 


recorded by a person wearing a film badge 


would have been higher than the actual, 


actuality is what I’m trying to get out, 


because of the criteria. Basically the dose 


that would have been recorded by the film 


badge would have been higher than what the 


employee would have actually received, and I 


thought that was of interest to relay. 


MR. HINNEFELD: I didn’t quite follow that. 


MR. ROLFES: All right. I apologize. I’ll 


try to clarify. I guess the badges were 


calibrated with uranium metal slabs. And I 


guess because of the age of the material, I 


guess to allow for Protactinium in-growth, I 


guess some of the beta dose for a person 


working with fresh uranium metal, I guess some 


of the beta dose would have been, I guess --


MR. RICH: It would be lower than the 


standard. The calibration curve would 


overestimate the --


MR. HINNEFELD: You can explain it to me 


later. 


There was a point in time when the 


calibrations were done with radium, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

316 

calibration films were shot with radium with 


this and so they did that for the photon 


calibration. And I think the uranium slab may 


have been the open window calibration. 


MR. RICH: The skin dose. 


MR. GRIFFON: Do we have a set of reports 


that discuss the QA? 


DR. BEHLING: No, that issue is that we 


didn’t see anything. 


MR. GRIFFON: As an action is there anything 


that we can follow up on this to find more 


supporting documentation that would say there 


is a QA program going back to the early years. 


It might be worth us seeing more documentation 


to support that is all I’m saying. 


MR. ROLFES: We’ve been told that 


instructions did exist, but we haven’t been 


able to locate them. And we should probably 


look in Oak Ridge as well. 


MR. GRIFFON: I mean, I would say as an 


action item, attempt to recover those kinds of 


supporting documents. 


MR. HINNEFELD: What do you expect them to 


find along those lines, Mark, in terms of QA 


program? What would you think would be 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 -- 

23 

24 

25 

317 

evidence of that? 


MR. GRIFFON: I guess I would, wouldn’t 


there be some sort of quality assurance 


reports or QA reports or sections of the 


Health Physics reports that might have a 


section on quality assurance? 


MR. CHEW: How about in a comparison study? 


MR. GRIFFON: Yeah, in a comparison study. 


DR. ZIEMER: Of facilities? 


MR. HINNEFELD: Well, the first ones I’m 


aware of were the preparatory evaluations for 


Golab*. 


DR. ZIEMER: That would be much later. 


MR. RICH: During the early days the Oak 


Ridge badge was used at most of the 


facilities. That was the first one out of the 


box, and so as a consequence I do know in the 


early days there was inter-comparisons between 


the laboratories. And I’m not sure that 


Fernald participated in those. 


MR. HINNEFELD: Oh, yeah, I don’t know about 


MR. RICH: I don’t know about Fernald 


specifically, but I do know what was --


DR. ZIEMER: Internally many facilities will 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

318 

expose badges intentionally to see if the 


technicians who read it out get the right 


value. It’s at least an internal check. They 


may be completely off compared to the rest of 


the world, but at least they’re consistent 


internally. So you need both I think. 


MR. CHEW: Mark, I think we understand what 


you’re trying to go for. So maybe the action 


item is that we’ll make an attempt to look for 


some control for the dosimetry badge process. 


MR. RICH: Then again, it was the Oak Ridge 


technology that was used at Fernald just like 


other plants. 

MR. FAUST (by Telephone): This is Leo. 

DR. ZIEMER: Hi, Leo. 

MR. FAUST (by Telephone): That dosimeter 

was the Oak Ridge dosimeter, and it was 


included in many inter-comparison studies with 


other sites including Hanford. And it did 


compare very, very favorably. And that’s 


documented in some of the Parker papers. 


The other thing that occurs is when 


the badge was calibrated, it was in fact 


calibrated to a uranium slab. And it was 


exposed on an individual that wore clothing, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

319 

and the clothing actually attenuated the dose 


of the uranium by about 20 percent. The badge 


did not have the intervening clothing between 


it and its source. So the net result would be 


that the badge would actually give an exposure 


that was higher than what the individual 


actually received. 


MR. ROLFES: A much better job of explaining 


that than myself. So thank you, Leo. 


DR. ZIEMER: Leo, do you know the particular 


Herb Parker reports or are they Hanford 


reports or --

MR. FAUST (by Telephone): It’s in the Herb 

Parker --

DR. ZIEMER: In the book? 

MR. FAUST (by Telephone): That book on 

Parker. I’ve got it some place around here. 


DR. ZIEMER: You can track it down. 


MR. FAUST (by Telephone): Story I think. 


And we’ve referenced it at several different 


times, and it’s on the, I think it’s on the O 


drive quite frankly. It’s called Herb Parker, 


Herbert M. Parker. 


It’s a compendium of a bunch of his 


personal papers and letters and speeches and 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

320 

that sort of thing put together by Baehr* and 


Kathryn* and somebody else. 


MR. CHEW: Leo, did the years that Herb’s 


study or assessment, was it covered in the 


book there? 


MR. FAUST (by Telephone): I didn’t get 


that. Please repeat it would you, please? 


DR. ZIEMER: What years did he cover in his 


report? 


MR. FAUST (by Telephone): I think the very 


first one was like 1948, and it goes up 


through --


DR. ZIEMER: Okay, the early years. That’s 


what we wanted. 


MR. FAUST (by Telephone): I know, but it 


starts there around ’48 or ’49 and it goes up 


through the ‘50s and ‘60s. 


MR. CHEW: We’ll take a look. 


MR. FAUST (by Telephone): The other thing, 


I’m trying to track down some people that we 


interviewed and talked to by phone insisted 


that there were written instructions of one 


sort or another that governed the processing 


of the dosimeters. And I’ve got all of the 


Health and Safety laboratories because they 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

321 

did the first 15, 18 months of processing. 


And I’m trying to track down something out of 


the Oak Ridge organization that may have 


governed the use of that dosimeter. 


MR. CHEW: Thanks, Leo. 


DR. MAKHIJANI: I have a question about a 


later period that you raised about when TLDs 


were first introduced and they had that 


adjustment factor to account for the 


contamination of the TLDs and sometimes 


resulting in negative radiation doses. It’s 


in volume four of the Westinghouse Transition 


Report. It’s in our TBD review. 


And I was told that these readings 


were never entered into the worker dose 


records, but I’m not convinced, by my reading 


of the Westinghouse Transition Report, I think 


they were, the corrected readings were 


entered. And when they had a correction of 


more than 50 percent, they said -- or negative 


radiation dose -- they referred them to Health 


Physics. 


But there’s no indication of what 


happened. That’s a black box. And I think 


there’s an 18-month period in 1983 to ’85. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

322 

I’ve written it up in the TBD review, but it’s 


nowhere addressed what happened to these 


correction factors that were obviously wrong. 


I mean, they were yielding results that were 


not physically possible in some cases. 


MR. CHEW: Do you remember anything like 


that? 


MR. HINNEFELD: I remember it. I was 


thinking it was for skin doses only, but I 


could be wrong. 

DR. MAKHIJANI: I do believe so. I think it 

--

MR. HINNEFELD: Yeah, it was, well, the 

practice started -- gosh, a little history 


here. The practice started because when 


Fernald first switched to TLDs from film, they 


started getting skin dose-to-gamma ratios that 


were far larger than anything they’d seen and 


skin doses that were far larger than anything 


they’d seen on the film even though their film 


badge had performed well in the early Golab 


accreditation, you know, getting ready for 


Golab, and those inter-comparisons to film had 


really done pretty well. And so there was 


this puzzlement about what had happened here, 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

323 

and there was speculation that construction of 


the badge gave rise to a, there’s a small 


ledge on the face of the badge right in front 


E-1, Element One. That’s why I was thinking 


it was a skin dose adjustment. Where that 


became contaminated because Fernald was a 


contaminated environment, you would have an 


extraordinary large dose from that 


contamination on E-1, the first element of the 


TLD, and skin dose was derived from the ratio 


of Element One to Element Two, so you get a 


very high ratio and therefore, a very high 


dose that was incorrectly attributed to the 


dose to the skin when based on that little bit 


of contamination on the badge. So that was 


the speculation, and that’s what gave rise to 


this contamination adjustment factor. It was 


contamination on the badge, and how we would 


adjust that. I think really what happened, 


the real problem with the dosimeter was that 


the algorithms were converting the E-1/E-2 


ratio into skin dose was incorrect, and it 


took a few months to figure that out. 


DR. ZIEMER: This was a commercial vendor 


and all? 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

324 

MR. HINNEFELD: This was Panasonic TLD 


inside of a Fernald badge because it was still 


a Fernald security badge. So it was --


DR. ZIEMER: Read out here? 


MR. HINNEFELD: Yeah, read at Fernald. But 


the algorithm for conversion was developed by 


the University of Michigan, and they did the 


preliminary testing of the badge, the 


Panasonic TLD in the Fernald badge, did the 


exposures, the radiations, and developed the 


algorithm for converting the E-1-to-E-2 ratio 


into skin dose. 


And the error came there, you know, 


came back from the algorithm. Took a few 


months to sort out that this algorithm isn’t 


right. And then that gave rise to some more 


with Idaho to come up with another, you know, 


what would be a better approximation algorithm 


for the E-1-to-E-2 ratio. So the error in the 


algorithm was that they put a polynomial with 


five data points, four of the data points were 


on one end of your data range, and the other 


one’s at the top. 


And so you’ve got this kind of a funny 


looking thing like this which should have been 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

325 

a uniformly assembled curve. So that was the 


evolution. That’s how it started. That was 


the origin of that factor, and the end of the 


factor was sort of a recognition that, hey, 


you know, dosimetry results should be right on 


the individual case not on the average, 


whereas, there might be an average 


contribution. 


I think the contamination adjustment 


was derived empirically, you know, get some 


bad news, to a certain extent, find out, you 


know, just leave them and read them and find 


out what dose you get on that badge based on 


contamination level. I think that’s how the 


adjustment was developed, but and that’s sort 


of an average approach to things. It just 


seemed like the dosimeters ought to be correct 


in the individual not in the overall average. 


And so the practice was suspended 


before, shortly before the Westinghouse 


transition, before they took over. So that’s 


my recollection of it. I really thought it 


was only a skin dose adjustment though. 


DR. MAKHIJANI: Maybe, and I may not be 


remembering it right. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

326 

MR. HINNEFELD: That’s my memory of what the 


evolution of it was, and it was strictly a 


skin dose, E-1/E-2 ratio explanation that gave 


rise to that. I think that’s the case. I 


won’t swear to that, but I think that’s the 


case. 


DR. MAKHIJANI: I may not be remembering it 


right, but some examples, actually, it doesn’t 


say here. But some examples are given in 


Table 9 of our TBD review, and they’re drawn 


from --


MR. HINNEFELD: Yeah, a contaminated badge, 


an unusually contaminated badge --


DR. MAKHIJANI: They’re all over the map. 


MR. HINNEFELD: -- and it would blow that 


adjustment factor. Clearly, it couldn’t have 


been correct as you said. It was just the 


fact that it was bigger than the measured 


dose. So that did happen. In those cases the 


adjustment factor wasn’t applied correctly, 


and there were probably maybe a dozen. And I 


don’t really recall the resolution of that. 


As you said, above a certain fraction it was 


referred to somebody for investigation, but I 


don’t really recall the outcome. How those 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 -- 

22 

23 

24 

25 

327 

investigations were conducted. 


DR. MAKHIJANI: And when we raised this 


issue in a conversation with NIOSH, NIOSH 


said, oh, the doses were not entered into the 


dose record, but that’s not the impression I 


got --


MR. HINNEFELD: See, I don’t know whether 


that’s true or not. 


DR. MAKHIJANI: -- from reading the 


transition document to my knowledge the 


issue’s never been resolved. 


MR. HINNEFELD: I don’t know. Originally, 


they were recorded I believe, as the adjusted 


doses I believe were originally recorded. 


They could have been backed out, you know, 


uncorrected later on, but I don’t recall that 


they ever were. 


MR. GRIFFON: So we need an action follow up 


on this? 


DR. MAKHIJANI: Yes, I think we need to know 


MR. GRIFFON: This doesn’t really fall under 


any of the findings, does it? 


DR. ZIEMER: It’s sort of performance 


standards of personnel dosimetry. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

328 

DR. MAKHIJANI: In the TBD finding, finding 


number 19, no, sorry. It’s finding 20 in the 


TBD review. Correction factors used during an 


initial period of use of TLDs at Fernald are 


not scientifically appropriate. So --


 MR. CLAWSON: And under our matrix that 


would be 4.5-1? 


DR. BEHLING: No, it wasn’t discussed. 


DR. MAKHIJANI: No, it wasn’t discussed in 


the matrix. It’s just, it’s covered under 


that umbrella item, but I think it sort of 


falls into the finding we’ve just been 


discussing except we’re doing specifically 


(inaudible), but it should be, I think there 


should be some resolution for this question. 


MR. FAUST (by Telephone): This is Leo 


again, and I could very well be mistaken, but 


it was my understanding that during that 


transitional period the Oak Ridge dosimeter 


was still used, and that that was the dose of 


record. That may or may not be correct, but 


that’s my understanding of it. 


MR. HINNEFELD: Now, Leo, the Oak Ridge 


dosimeter stopped, using the Oak Ridge 


dosimeter stopped when the film badge was 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

329 

adopted. There were maybe one or two months 


of overlap, but by the time you get into the 


Westinghouse transition period, they’d been on 


TLDs for about a year or so at that point. 


Well, I mean, there was a very short 


period of time when people wore both, the TLD 


badge and the film badge that they’d worn 


before, a sort of inner comparison. And then 


after that it went straight to TLD. 


DR. MAKHIJANI: My impression, if it had 


just been experimental, I think there would 


not have been this issue in the transition of 


what happened with all this with readings 


given and correction factors and so on. So 


that’s why I say that it appears, although I’m 


not sure, but it appears to me that these were 


doses that were attributed to individuals. 


MR. HINNEFELD: They originally -- I’m 


pretty confident -- originally there was some 


adjustment made before the dose was recorded. 


That’s my understanding. I’m pretty sure that 


did happen. I don’t know if later on they 


were unadjusted retroactively. I don’t know 


if that happened or not. 


DR. MAKHIJANI: I don’t know. So this is 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

330 

something that obviously needs to be resolved. 


MR. CHEW: Do you want to state the issue, 


Mark, so we all understand it? 


MR. GRIFFON: I have general actions at the 


end of this, but I didn’t tie it to any matrix 


item, and this is one of those. I said NIOSH 


would follow up on the doses assigned in the 


beginning years with the use of the TLD badge 


and what data was recorded, and I think that 


captures the question. And beginning years 

I’m saying ’83 to ’85. Is that the time 

period? 

DR. MAKHIJANI: Yeah, I think that timeframe 


is given in the transition report. I think it 


was 18 months or two years or something like 


that. 


MR. HINNEFELD: Sounds like it would have 


been, yeah, sounds like it would have been 


from early ’83 to middle of ’85. 


DR. MAKHIJANI: I think so. I think it was 


something like that. Maybe it was 30 months. 


MR. HINNEFELD: Yeah, it may have been. It 


may have been ’84. When the heck did it 


change? 


DR. MAKHIJANI: I don’t remember. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

331 

MR. HINNEFELD: I don’t remember when. 


Somewhere in there, ’84, ’85. 


MS. BALDRIDGE: There is some mention in one 


of the documents in the petition about them 


enclosing the badges in plastic bags, and why, 


the reasoning for that so there might be some 


insight. 


MR. HINNEFELD: Yeah, the plastic bag was an 


attempt to keep the badge from getting 


contaminated so we wouldn’t have to worry 


about this adjustment. We didn’t have to 


worry about the badge getting contaminated. 


Throw away the plastic bag and --


MR. FAUST (by Telephone): That’s a non-


issue anyway because the bag was, when the 


procedure was put into place, enclose the 


badge in a plastic bag, it was also calibrated 


in that plastic bag. And that would have 


taken care of any discrepancies between the 


unplastic bagged dosimeter and a bagged one. 


UNACCOUNTED DOSES TO EXTREMITIES
 

DR. BEHLING: Finding 4.5-2 is unaccounted 


doses to extremities, and I know that, at 


least for some people, wrist badges were 


given. As was already mentioned, the ratio 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

332 

between skin dose and deep dose are the ratio 


varied considerably over time. And I’ve 


discussed some of the numbers that were cited. 


The ratios in some instances were as high as 


20-to-one, and then they were reduced to five-


to-one. So there were periods of time when 


skin doses were extremely high and probably 


due to the presence of Protactinium and 


exposure to that. 


And in one of the documents that I 


enclosed as Attachment 4.5-2B, the following 


statement appears: “NRO has performed a study 


of exposures to the forearms of some Plant 5 


employees. The results of the study showed 


projected annual forearm exposures from about 


14,000 to 46,000 millirem. According to NRO 


estimates about 300 employees would require 


extremity monitoring because of potential 


exposures to their hands. It appears 


necessary that further attention be given by 


NRO to this matter.” 


And I guess the question I have is how 


many people may have been exposed to large 


extremity doses but were not monitored. And 


we can’t necessarily rely on a ratio that is 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

333 

highly variable as a function of time. And I 


know that some people wore wrist badges, and 


we can make adjustments on behalf of those 


wrist badges. But did everyone who may have 


been exposed to their forearms handling 


uranium necessarily have wrist badges? 


DR. MAKHIJANI: Well, just as an addition to 


that I think that wrist monitoring started in 


1970. Is that right? I think that’s the --


MR. HINNEFELD: ‘Seventy-seven? 


DR. MAKHIJANI: -- so before 1970 there was 


no extremity monitoring data to my --


MR. HINNEFELD: I think it was 1977. I 


don’t think it was 1970. I think it was ’77 


just from the stuff I’ve read. 


 MR. ROLFES: Once again, this would be a 


limited subset of claimants that we would be 


doing dose reconstruction for. This would 


have to be essentially a skin cancer on the 


individual’s hand, and anyway, we do have data 


for extremity doses recorded at Fernald. 


And the obvious application of this 


data would be important for a skin cancer 


located on a person’s extremity. That would 


be the application. Very few claims would be 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

334 

affected. The total number I could give you, 


but anyway we do have extremity doses that 


were made using those wrist dosimeters and a 


wrist-to-extremity ratio. 


The ratio varied with the changes in 


the dosimeters. It actually did decrease with 


the introduction of the TLDs; however, we 


don’t believe that there was an adjustment, a 


retrospective adjustment to actually correct 


the over-reported doses to the extremities. 


These are also things on a, these evaluations 


can be done on a case-by-case basis. 


And we don’t feel that this is an SEC 


issue because this can be bounded based on 


claimant-favorable assumptions and source term 


information as well. 


DR. MAKHIJANI: Is there a model for this 


especially before 1977 or coworker model or 


how did you handle it? 


 MR. SHARFI: This is now really different 


than geometry which is essentially glove box 


work really. 


MR. HINNEFELD: It’s really not much 


different than that. 


 MR. SHARFI: We’re basically talking about 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

335 

basically geometry. 


MR. HINNEFELD: It’s a geometry adjustment. 


 MR. SHARFI: Right now like for Rocky we had 


to look at hand-to-wrist, and wrist-to-hand 


ratios. I don’t think this would be any 


different. 


MR. FAUST (by Telephone): You guys, there 


was a big study done by Joan in determining 


what that ratio was, and the finding or the 


results of her study indicated that the ratio 


was actually less than what the ratio was that 


was being used to find extremity doses, but no 


adjustment was made to account for that 


lowering. It was left the way it was. I’m 


sure that happened while you were there, Stu, 


in the late ‘80s probably. 


MR. HINNEFELD: I remember her study, and I 


don’t remember what all she investigated, but 


I was under, I did think that that had been 


sorted out. But there is a reasonable ratio, 


if someone does not have extremity monitoring, 


it does not mean that their extremities were 


not more heavily monitored and they were more 


heavily exposed on their whole bodies. 


So if they have a cancer on the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

336 

extremity, you have to make an adjustment for 


the measured dose to account for the extremity 


to the ratio between the badge and the 


extremity. And I’m pretty sure it’s 


available, if you say that Joan’s study has it 


in there, I don’t recall that specifically. 


It could very well have it in there. 


It seems to be a pretty tractable 


issue. I mean, the jobs that gave rise to 


hand dose compared to whole body dose I think 


are pretty easily recognizable. And as long 


as you’ve got data from those jobs, I think 


you can bound that ratio. 


MR. FAUST (by Telephone): This was actually 


a ratio between a wrist dosimeter the 


extremities rather than a whole body dosimeter 


and the extremity. 


MR. HINNEFELD: I think even then in many 


cases you’ll have to (inaudible) the ratio to 


the whole body badge because a lot of people 


only have a whole body reading, and you’re 


going to need that ratio, but I think that is 


a tractable problem. I think if there are 


data available that allow you to do that from 


various time periods, they may be a later time 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

337 

period, but the physics of the radiation from 


the material isn’t changed over the 40 years 


of the operation. 


MR. ROLFES: From working on this project 


for, I guess, five years I’ve probably seen 


two cases where there have been extremity skin 


cancers. Other cases that I’ve reviewed I’ve 


probably seen two that I recall where we had 


indication that the person was monitored for 


extremity dose in a later time period, and 


what we did is actually use the rem from the 


time period, for the time period that he 


wasn’t monitored. We had basically used his 


data from a later time period and basically 


made sure -- I believe Mutty may have been 


involved in --


 MR. SHARFI: I also quit the case. 


MR. ROLFES: Back and forth between us a 


little bit. We wanted to make sure that we 


filled in the gaps in the data with claimant-


favorable extremity dose. 


 MR. SHARFI: I believe later in his career 


he did have extremity dose, and we could 


(inaudible) his personal (inaudible) of 


geometry, et cetera, (inaudible) since he had 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

338 

some extremity dose. We could look at the 


dose badges that he had, both full body and 


extremity, we could calculate his own ratio. 


And then at that point we could apply, we 


could back calculate that to a ratio to all 


his other full body dose to his extremities. 


MR. GRIFFON: You don’t have any procedure 


right now for Fernald? 


 MR. SHARFI: That would have been a case-bycase --


MR. GRIFFON: Case-by-case --


 MR. SHARFI: It was such a rare situation 


when we do have an extremity cancer, not to 


say that we’ve done a --


MR. GRIFFON: I think there’s a few of them. 


I’ve looked at a couple Fernald cases recently 


that there’s cancers on the temple and neck 


and head. And it raises this question of the 


derby workers where we’ve heard testimony that 


they were going in these things cleaning them 


out, and if their whole body badge is 


representative of what their head getting to 


their upper extremity, you know? 


DR. MAKHIJANI: There is that, yes. The 


workers put their heads in the graphite 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

339 

crucible --


MR. ROLFES: The difference in dose reported 


by the whole body dosimeter versus the head 


would in my opinion be much less than the 


factor between the whole body badge and the 


extremity. 


DR. MAKHIJANI: Well, I don’t know. In this 


situation --


MR. GRIFFON: It’s a badge situation. 


DR. MAKHIJANI: You’d have some shielding 


from the crucible itself because --


MR. GRIFFON: And it’s really inside. 


DR. MAKHIJANI: And then I think that there 


a quotation and a description of this 


particular problem in our TBD review. It came 


up in a worker interview. And it is in an 


appendix, the full interview is in the 


appendix to our TBD review. And it was 


explicitly culled out in the body of our 


analysis. 


MR. GRIFFON: But I think I tend to agree 


with Stu. I think it’s a tractable issue, 


and, I mean, what’s our other recourse here. 


It’s not a listed SEC cancer so realistically, 


we’re going to --

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

340 

DR. MAKHIJANI: That doesn’t matter --


MR. GRIFFON: That doesn’t matter, exposures 


exposure, I know. 


DR. MAKHIJANI: No, no, but for SEC you’ve 


got to cover all the cancers even though 


they’re not among the... 


SKIN/CLOTHING CONTAMINATION
 

DR. BEHLING: On the next one, this 


addresses the issue of perhaps shallow and 


even deep doses that are not necessarily 


monitored that could have resulted from 


skin/clothing contamination. I will accept 


the notion that people were monitored while 


they were at work. 


But you also have to accept the notion 


that this was not a very clean environment in 


which they worked. Add to that the fact that 


they were not normally provided anti-cees and 


even in the, as late as a 1985 report, the 


observation was as following: “There are no 


contamination survey instruments kept at the 


work site for use in checking for skin and 


clothing contamination. Neither are there 


hand or shoe counters available to use before 


or after showering.” 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

341 

And it goes on further to discuss 


other issues involving the limited effects of 


showering that were not necessarily abided by 


by our own people. Now the question is to 


what extent can a persistent skin 


contamination or even clothing if a person 


wears the same clothing day-in and day-out, it 


keeps it in a locker and the thing’s just 


laced with contamination. Is he receiving a 


very high skin dose that is not necessarily 


monitored by his whole body badge? 


And obviously, even if it is, during 


the time it’s worn the fact is the badge stays 


home and he goes home and he wears the same 


clothing. And if it’s a persistent skin 


contamination that may be there for days and 


days and days. And of course, that is not 


going to be monitored by a badge that’s 


hanging some place else. 


So the question is again, based on the 


fact that this was a fairly dirty environment, 


there’s likely to be a significant number of 


skin exposures that will not be properly 


monitored because this simply, the data isn’t 


there. In fact, what I have here was on one 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

342 

of my attachments early on. 


And this was in light of the issue 


surrounding thorium, but there a particular 


memo that I included here. This is on page 61 


of my report that talked about the cleaning of 


the under burnout oxide conveyors in Plant 5. 


And it talks about something that really in 


this day and age would (inaudible) anybody 


out. It talks about up to about a year the 


operator had to position himself under the 


inspection plate to remove it for access under 


the oxide conveyor. 


This caused much of the oxide to come 


down upon him. Breathing zone samples 


resulted from this operation were found to be 


9.3 million DPM per cubic meter. So this is 


an incredible high air concentration that was 


measured by an air sampler. And this stuff 


obviously he was laying on his back face up, 


and this stuff would come down. 


And so you can imagine the kind of 


skin contamination on his face, especially in 


his hair that he would have received from when 


this kind of operation took place. And I 


think it was one that wasn’t necessarily 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

343 

monitored or dealt with in terms of 


decontaminating the individual. 


So it’s just an issue here that I 


wanted to bring out about skin cancers, and we 


have to be very mindful of potential skin 


cancers that will not be properly assessed 


based on whole body dosimeters that may not 


have been very effective in assessing 


exposures as a result of persistent skin and 


clothing contamination. 


And as I said, there were no anticees, and there were no frisking of personnel 


at the end of a shift who were coming out of 


an RCA area. And so we have to deal with the 


unknown that says there may have been very, 


very profound skin contaminations. 


MR. ROLFES: We don’t feel like this is an 


SEC issue because we feel that we can bound 


this issue. We can bound the dose from skin 


contamination --


DR. BEHLING: But it’s not monitored. If 


you have data, you can certainly make an 


attempt based on DPM per unit of area you can 


come up with some assessment of skin dose, but 


where you don’t monitor it, and you don’t 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

344 

document it, what do you have to work with? 


MR. ROLFES: Well, we could look at the 


dosimetry results which we have because if the 


contamination was in proximity to the 


dosimeter being worn, that would, in fact, be 


recorded by the dosimeter. 


DR. BEHLING: Partially. 


MR. ROLFES: The other issue is we could do 


a VARSKIN calculation to determine a ballpark 


estimate and pretty much demonstrate that dose 


from skin contamination is relatively low. 


Dose rates from skin contamination is 


relatively low. The workers did typically 


take frequent showers before lunch and before 


going home so any physical skin contamination 


would have been observed and would have been 


removed at the time of taking a shower. So 


it’s possible that some contamination, we know 


for a fact that if you review the historical 


photos that this occurrence did, in fact, it 


was routine, you know, the head skin 


contamination. 


MR. GRIFFON: Is that true? They showered 


before lunch and going home? 


DR. BEHLING: Let me read to you something 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

345 

on that issue. 


MR. GRIFFON: That surprises me especially 


in the old days that that would have been a 


practice. 


DR. BEHLING: In fact, this is Attachment 


4.5-3A page 124. Let me read to you on page 


124 of the report. It makes reference to the 


drum bailer in the drum reconditioning 


building only those men involved in the 


cleaning the bailer will be required to make a 


complete clothing change. Only those so 


obviously you were highly restrictive request 


for clothing change to people, certainly not, 


this was not a universal requirement. 


MR. HINNEFELD: I think that pertains to a 


special clothing change mid-day, during while 


you’re out there. There was particular 


occasions -- this doesn’t speak well for the 


cleanliness of the plant -- there were 


occasions when people would get so dirty from 


whatever job they were doing that supervisors 


would send them or they would give them 


permission to go now, shower and change into a 


new set of clothes because they wore company-


issued clothes. Go now shower and change and 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

346 

then come back out without waiting to go to 


lunch. 


And there was a shower, in order to 


get through the locker room, you had to go 


through the shower. So you could 


intentionally avoid the shower, but to go from 


the locker room where you took off your 


company-issued clothes to the side of the 


locker room where your street clothes were, 


you had to go through the shower. 


MS. BALDRIDGE: I believe there’s a document 


in the petition where it describes them 


laundering the wool and the cotton filter bags 


from the air collectors in the same facility 


that they’re laundering uniforms. I don’t 


know what kind of --


MR. GRIFFON: Reissuing contaminated --


MS. BALDRIDGE: -- right. 


MR. MORRIS: Every facility in America does 


that. They have a lower detection threshold 


cut out from recycled coveralls and I don’t 


know of any reactor that doesn’t have that. 


 MR. CLAWSON: It also came up with an awful 


lot of europium, lot of other isotopes even 


around coming back and giving them to other 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

347 

people. And we’ve got that today. 


MR. GRIFFON: But if this was really the 


policy that they showered after their shift, 


for sure they showered before they went home, 


then I would see this as kind of a minimal 


potential here --


DR. BEHLING: Well, I’ve seen persistent 


steam contaminations that days and days and 


days of scrubbing wouldn’t take off. So a 


simple shower is hardly adequate to ensure 


that there’s 100 percent removal. 


DR. MAKHIJANI: It may be useful to do a 


sample VARSKIN contamination. Mark, would it 


be useful to do a sample VARSKIN contamination 


for the case that --


MR. MORRIS: Yeah, we’re in the process of 


doing that. 


DR. MAKHIJANI: No, for the particular case 


that Hans read out which is that infamous 97. 


MR. MORRIS: Well, obviously some of that is 


going to fall off. You know, it’s not going 


to stick on like glue. It’s not going to be ­

-


DR. MAKHIJANI: I’m not telling you how to 


do the calculation. I’m just saying it would 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

348 

be interesting to see an example --


MR. GRIFFON: What kind of doses are we 


talking about? 


DR. MAKHIJANI: Assuming that, I think the 


job lasted for five hours or something. I 


think it says in the first memo. The page of 


the memo is not in the report, but it actually 


says in this memo how long the job lasted. 


Well, you could do the calculations --


MR. FAUST (by Telephone): Somebody was just 


mentioning the therapist dose rate for an 


infinite slab of uranium is 230 plus or minus 


a few rads per hour. And if anybody’s going 


to get any negligible dose, you should be able 


to see the uranium. It’s inconceivable to me 


that anyone can have a dose of any concern 


whatsoever from residual contamination on his 


skin, and certainly not on his clothing 


because if it’s any magnitude at all you can 


see it. 


MR. CHEW: Well, Arjun is shaking his head 


positive so maybe we can stop there. 


 MR. CLAWSON: One thing that Hans says about 


the shower and so forth, this is from personal 


experience and wearing a glove for a week and 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

349 

a half, it doesn’t all come off. So, you 


know, I’ve done the scrub. I’ve done the 


whole nine yards. There’s still, you know, it 


may not be not much, but it’s something that 


we need to be able to address because I think 


especially with this facility. I think it’s 


something that we need to look at a little bit 


closer. 


MS. BALDRIDGE: And not everyone wore a 


uniform. A lot of the contractors worked in 


their street clothes and left in their street 


clothes and took it home. 


MR. HINNEFELD: That would be true of 


contractors. There were probably contractors 


who did not change out and probably wore their 


own clothes. 


MR. GRIFFON: So they walked through that 


shower with their clothes on? 


MR. HINNEFELD: They would not have gone 


through that shower. No, 


MR. GRIFFON: So there was other ways to get 


out of there. 


MR. HINNEFELD: If you didn’t change into 


company clothing, you didn’t have to go 


through that shower. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

350 

DR. ZIEMER: What about portal monitors? 


MR. HINNEFELD: Not until mid- to late-’80s. 

DR. MAKHIJANI: So what do we do about that 

one? 

MR. GRIFFON: Still, you’ve got this uranium 


limitation. I mean, the physical limitation 


we still have, but I don’t think you have any 


way to address assigning additional dose to 


people that, you know, to contractors that may 


have, I mean, even though it would be small, 


and there’s no current method for assigning 


additional dose, missed dose sort of? 


DR. MAKHIJANI: Yeah, that’s what I’m 


asking. Is there a procedure? I didn’t see 


it in the --


MR. GRIFFON: I’m sure there’s not. 


DR. MAKHIJANI: I did not see it in the 


construction worker. I don’t remember. 


MR. HINNEFELD: I don’t think the 


construction worker addresses it. I think 


NIOSH has an action here to kind of come up 


with some discussion about is there some sort 


of logically bounding or logical approach 


about this. Because there were certainly 


people got it on their skin and got it on 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

351 

their clothes. And clothes that came out of 


the laundry weren’t necessarily completely 


decontaminated either. So there may be some 


necessity here to at least decide is this 


something we have to account for or not. And 


if not, why not? 


DR. MAKHIJANI: As a helpful thing perhaps 


you might, we had this discussion at Bethlehem 


Steel, and there was a different facility with 


uranium and steel mixed in. You have to 


discount for that, but there a methodological 


discussion around, and it might be useful to 


revisit it. 


DR. BEHLING: And while the dose rate even 


from a slab is a little, but I realize that 


some of these people worked there for years. 


And so even a modest dose integrated over a 


long period of time, you’re not dealing with 


inconsequential skin doses. 


DR. MAKHIJANI: I agree with Hans. I think 


if I’m recalling even at Bethlehem Steel after 


we were done assuming that people wore their 


clothes all, the kind of scenario that Sandy 


is talking about. I think once you get into 


people wearing the same clothes that were 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

352 

contaminated, then the doses became non-


negligible although I’m saying this from 


memory. Jim Neton would know because he was 


involved in resolving that issue. 


 MR. CLAWSON: It was something that was they 


wore their clothes every two or three days and 


laundered and so forth? 


DR. MAKHIJANI: Yes. 


 MR. CLAWSON: I just vaguely remember 


something like that. 


MR. GRIFFON: Yeah, the details on that. 


DR. MAKHIJANI: Ed Walker who supplied that 


information. 


NEUTRON DOSES
 

DR. BEHLING: The next one I think we may 


have partially addressed this morning 


regarding the issue of neutron doses. And 


again, I’m going back to the original TBD 


where they assess neutron/photon ratios for a 


single using repeated measurements and came up 


with a 95th percentile in gamma ratio 0.23. 


And I looked at that and said, well, I’m not 


going to contest empirical data. It’s there, 


and if it’s done properly that the value. 


But the question we had is a single 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

353 

necessarily a limiting factor in assigning 


neutron/photon ratio. And what we ended up 


doing was to run our own calculation. One of 


our people in-house, and some of you met him, 


ran a calculation using different 


configurations of drums. And what he found 


out -- and this is in Attachment 4.5-4A, and 


this is now on page 132 of the report. You 


can look at the n/p ratios that we calculated. 


And for a two percent enriched uranium 


drum array, we had an n/p ratio of 0.42 as a 


deterministic value. And that’s nearly twice 


the 95th percentile value that NIOSH had 


derived. So we’re nearly double, but we’re 


using a deterministic approach rather than the 


95th percentile. So that’s more an average. 


And, of course, that significantly 


different from what you calculated. But then 


again you say you have empirical data that you 


have looked at that will support the earlier 


n/gamma ratio 0.23. Now, we haven’t seen that 


data so this is an open-ended issue. 


MR. ROLFES: It’s one of our actions. We’ll 


provide that information to you. 


MR. MORRIS: I wanted to make a 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

354 

clarification. Dr. Ziemer --


MR. GRIFFON: I’m sorry, let me capture that 


action before you say anything else. 


MR. ROLFES: Earlier from our presentation 


we had been discussing the measured neutron 


dose rates, and then, but this was from 


Warehouse 4B these measurements were 


conducted. 


MR. GRIFFON: So you’re going to provide the 


data. 

MR. ROLFES: Yes, we’ll provide this 

information. 

MR. MORRIS: To make that clarification, Dr. 

Ziemer has asked the question what kind of 


instrument was used to make the measurements 


and Leo Faust has told me that the record 


shows the instrument was a Nuclear Research 


Corporation model NP-2 which is the Snoopy 


that some of us know about. It had its own 


readout, but in low dose rate measurements it 


could be used with an integrating meter to 


select a variable period of monitoring time. 


And for these measurements a ten minute 


monitoring period was used. It was calibrated 


offsite to a plutonium-beryllium standard. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

355 

DR. BEHLING: Is that instrument energy 


sensitive? 


MR. MORRIS: Yes, it is, just like United’s 


Trim Meter. It’s got a very similar energy 


response curve. 


DR. BEHLING: And the plutonium-beryllium 


has what? A five meV average neutron energy? 


MR. MORRIS: They tend to over-respond. 


United Trim Meters and Snoopies together alike 


tend to over-respond in the middle energies 


under keV up to one meV sometimes by a factor 


of two. The higher energy calibration will 


offset that to some extent compared to the 


californium calibration, but still you get an 


over-response than this would have been. 


 MR. CLAWSON: Arjun, before he leaves then, 


we’ve only got one more to go. 


UNMONITORED FEMALE WORKERS
 

DR. BEHLING: Two more, yes, and the last 


one involved unmonitored female workers. 


We’re at the last. I never thought we’d even 


come close. And the reason we brought this up 


is because there is an accepted statement in 


the TBD that women were not monitored for 


various periods of time. But one of the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

356 

things that was also just brought up, the 


issue Sandra just brought up, was the 


commingling of perhaps laundry with collected 


dust bags. 


And in my report as one of the 


attachments, we see some activity levels in 


dust bags of, in those days it was reported in 


terms of millirem, up to five millirem per 


hour of after cleaning and 30 millirem before 


cleaning. And these things were laundered by 


women who themselves were neither monitored 


internally nor externally. 


And that also brings up the issue the 


came up subsequently. That is, what happens 


when you throw in those dust bags with other 


laundry that may be laundered and that people 


may wear as anti-cees. The question is, there 


are multiple aspects to this issue. 


Women who were consistently not 


monitored internally and externally, bags that 


had a fairly high contamination level that 


would have exposed them and potentially 


contaminated, cross-contaminated, other things 


that people would wear the next day. So we 


have a series of potential open-ended issues 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

357 

here. 


MR. ROLFES: Well, I think we addressed this 


in part in the current technical basis 


document by saying that if we have indication 


that a women was not monitored, we, by 


default, will assign 500 millirem per year to 


that individual, to that woman. And this 


actually exceeds by far the recorded doses 


received by many of the process operators at 


Fernald. 


So I believe that’s very defensible 


right off the bat. There’s other approaches 


that we could adopt to address this issue as 


well. By looking at what the individual was 


doing, the area that she was working in and 


look to see what kinds of doses the coworkers 


were being received -- excuse me -- what kind 


of doses her coworkers were receiving. 


There’s issues -- excuse me -- there’s 


approaches to this issue that we can adopt in 


order to bound these doses and so we don’t 


feel this is an SEC issue. 


MR. GRIFFON: You don’t have a coworker 


model for external right now. 


MR. ROLFES: There’s no coworker model for 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

358 

this. 


MR. GRIFFON: So you wouldn’t use the 50th or 


95th because you don’t have that data compiled. 


MR. ROLFES: No, exactly, we’ve been 


assigning doses, like I said, that actually 


exceed the recorded doses by production 


personnel of 500 millirem per year. 


DR. MAKHIJANI: I think a part of the 


resolution of this may be linked to the 


findings of the three women who were, who had 


the internal uranium burden --


MR. GRIFFON: Which you’re going to follow 


up with that. 


DR. MAKHIJANI: -- and you’re going to 


follow up on that. So I think we may link the 


resolution of this to the findings because you 


have high, very high internal dose due to some 


exposure. Then this may also become an issue. 


MR. FAUST (by Telephone): This is Leo 


again. The unmonitored females, I don’t know 


whether that included the lack of bioassay 


data or not, but I would assume that it did. 


I think there are several ways of assigning a 


plausible dose to your workers and Mark has 


suggested a couple of them. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

359 

Another one would be the same female 


during the periods that she was monitored, 


whatever that, and was doing the same job, you 


could assign that dose then to those periods 


of time when she was not monitored. And I 


think it’s pretty defensible. 


 MR. CLAWSON: That would be fine if all the 


processes were the same. Say (inaudible) 


issued them or whatever like that, it would be 


different filters. They may have started 


another process, and that means a little bit 


more background check into what had changed 


over the years if we were trying to use that. 


MR. GRIFFON: And again, the 500 millirem 


you reviewed production worker raw workers and 


just sort of determined that this is higher 


than the maximum? Or did you --


MR. ROLFES: I believe this approach was 


likely adopted from the five rem per year and 


the justification that it wasn’t necessary to 


monitor --


MR. GRIFFON: Sounds like it’s one-tenth of 


it, yeah. 


MR. ROLFES: -- someone if they didn’t have 


the potential to exceed ten percent of the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

360 

annual dose limits. 


MR. GRIFFON: So it’s going to the likely to 


be monitored if you exceeded the --


MR. SCHOFIELD: How much, was there a lot of 


in vivo done on any of these women? Any in 


vivo measurements, any urinalysis? 


MR. ROLFES: Well, we have documented the 


urinalysis results that Arjun and Hans have 


out earlier. The women did, in fact, 


participate at least in a physical -- excuse 


me -- in an annual physical where a urine 


sample was, in fact, collected from them. As 


far as in vivo, I’m not certain. 


In the later years it’s very likely 


that they were in fact. But I think this 


issue is more gear towards I think right 


around the 1960s when females weren’t 


routinely monitored. There’s a couple of time 


periods that are documented in our site 


profile for Fernald that indicates the time 


periods where women weren’t monitored. And in 


the more recent time period when women were 


working in the production area, those women, 


in fact, did have in vivo monitoring as well. 


MR. HINNEFELD: Was there a time period when 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

361 

people, women, were not monitored but they 


were allowed to go into the production area? 


MR. ROLFES: Not that I’m aware of. 


MR. HINNEFELD: I don’t even know. I mean, 


this predates me by a good bit, but I was 


always told that at the beginning of Fernald 


when they started up, women weren’t even 


allowed to go in the production area and so 


they weren’t badged. That’s what I was always 


told. 


MR. MORRIS: We heard in one interview that 


there were always exceptions that could be 


approved. If somebody wanted to visit for 


some specific reason that that could be 


arranged. But it was not a routine. 


MR. GRIFFON: So that policy would seem to 


support the 500 millirem being very claimant 


favorable. Is there any action on this one? 


I’m not sure other than following up on those 


other cases. 


DR. MAKHIJANI: I think the main action was 


to follow up on these two cases. Well, there 


were four, but one was a man. 


DR. ZIEMER: We tied that in with the other. 


 MR. CLAWSON: Well, then we did it. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

362 

MR. GRIFFON: Can I go back before we close 


up. We’ve got plenty of time left. 


The last item on the n/p ratio 


question, I just wanted to, I’m not sure it’s 


an action, but I think maybe I need to look at 


the report a little closer. Maybe it’s 


already been outlined. I haven’t looked that 


closely at this issue for Fernald. But the 


question we raised, Arjun raised, I think I 


mentioned it earlier, our experience with 


Rocky. 


And it’s not so much the comparison of 


the operations but the comparison of the 


approach using the n/p ratio and the 


appropriateness of it if you are, and I don’t 


know how. I’ve got to look. Maybe you’ve 


already outlined this, but it seems like 


you’re applying one n/p ratio across the site 


for all time periods. Am I wrong on this? 


MR. ROLFES: What we are assigning is the 


95th percentile --


MR. GRIFFON: Ninety-fifth, but it’s not by 


year by building. It’s for all time periods 


for all buildings or is it building-specific? 


MR. ROLFES: That’s correct. It’s across 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

363 

the board, 95th percentile. 


MR. GRIFFON: And is that, and that data, I 


mean, do you have any annualized data on this, 


the data that you’re going to provide? The 


survey data was only --


MR. MORRIS: It was only 1998. 


MR. GRIFFON: Nineteen ninety-eight. 


MR. MORRIS: I think 4B was 1998. 


MR. GRIFFON: So we don’t have anything from 


early periods or early time periods. I’m 


looking at this. 


MR. ROLFES: Off the top of my head I know 


that there are some other reports back in the 


‘80s. I believe late ‘80s. As far as prior 


to that I’m not aware of any. 


MR. GRIFFON: And I guess the one difference 


in, or one of the differences from what we 


were doing at Rocky is that at Rocky we had 


several different potential source terms for 


neutrons that complicated the matters for the 


ratios. So here you’ve got the one type of 


source term only. Is that pretty... 


MR. ROLFES: Well, there are potentially 


other source terms; however, the total 


contribution from neutron dose in everything 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

364 

that we’re aware of is very miniscule. 


MR. MORRIS: Thorium chloride was handled, 


but that’s such a low neutron emitter that 


it’s not even tabulated. 


DR. MAKHIJANI: But mostly it would be the 


uranium tetrachloride and the uranium 


hexafluoride in that brief period. I think 


the n/p ratio complication may come in because 


there’s also radium and things onsite. So the 


Plant 2,3, the raffinates, from the 


pitchblende and, you know. I’m not talking 


about neutrons from radium. I’m talking about 


the denominator of the n/p ratio. If the 


denominator goes up, then your n/p ratio will 


go down. 


MR. HINNEFELD: That would be relevant if 


data from there were used in developing the 


n/p ratio. 

DR. MAKHIJANI: That’s right. 

MR. HINNEFELD: If the data from somewhere 

else --

DR. MAKHIJANI: No, but I guess that only 

from the drum -- well, we just have to look at 


the way --


MR. GRIFFON: Yeah, we have to look at how 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

365 

you’re deriving --


MR. MORRIS: I think we understand that 


question. 


DR. MAURO (by Telephone): Morris, as a 


reminder though that attachment -- this is 


John -- that you referred to I think does 


place an upper bound, theoretical upper bound, 


which basically give you, really could not get 


a greater neutron-to-photon ratio and the 


value derived using that mc-np calculation we 


ran in the attachment to your report. 


DR. MAKHIJANI: For that physical 


arrangement. 


DR. MAURO (by Telephone): Yeah, the reason 


we made that arrangement is to create a 


situation where you get the maximum amount of 


shielding of the gamma so that because there 


are multiple containers stacked, and as a 


result you get the highest neutron-to-photon 


ratio. I forget the number. What was the 


number? If it was one or two or something 


like that? 


DR. BEHLING: Three four one. 


DR. MAURO (by Telephone): That’s a high 


number without a doubt, and we deliberately 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

366 

constructed as a plausible scenario because I 


think there were large amounts of, I guess it 


was uranium hexafluoride stored. And that is 


what we believe to be the highest neutron-tophoton ratio that theoretically possible. Now 


it may not have existed anywhere at the site. 


It’s important to note that though that there 


is a way to place an upper bound. And 


certainly, if you have some real measurements 


at real locations that show that, the reality 


is it’s lower than that. But I think it’s 


important to keep in mind that it is a 


tractable problem in terms of placing an upper 


bound on what it might be at the site. 


MR. HINNEFELD: I don’t know if this matters 


or not but in looking at the NP analysis in 


your report, the two percent array is a 


critically unsafe array. 

DR. MAURO (by Telephone): Is that correct? 

MR. HINNEFELD: Yeah. 

DR. MAURO (by Telephone): There you go. 

MR. HINNEFELD: Yeah, you wouldn’t stack 


three 65-gallon drums with two percent UF-4 


together. 


DR. MAURO (by Telephone): Then the number 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

367 

would be even more --


MR. HINNEFELD: You probably wouldn’t stack, 


in fact, we normally put it in cans. Or they 


normally put it in ten-gallon cans, but this 


would be a critically unsafe array. Normal 


(inaudible) be stacked. 


DR. ZIEMER: Then your neutrons are going to 


change. 


MR. HINNEFELD: Yeah, if you’ve got a ratio, 


you don’t want to mess with it. 


DR. MAURO (by Telephone): (Inaudible) 


change. 


MR. HINNEFELD: You could have a normal 


array in that arrangement, but you wouldn’t 


have a two percent array in that arrangement. 


DR. MAURO (by Telephone): Okay. 


MR. CHEW: Do you want to revise your 


theoretical calculations? 


DR. MAURO (by Telephone): I think I better 


fix that, right. 


MR. HINNEFELD: Use the normal drum array 


value. That’s very close to what we have. 


DR. ZIEMER: It’s good for a microsecond. 


DR. MAURO (by Telephone): I can’t wait to 


tell Bob that, Anigstein. I finally got him 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

368 

on one. 


 MR. CLAWSON: Any other questions? 


 (no response) 


 MR. CLAWSON: Clarifications? 


 (no response) 


 MR. CLAWSON: Lew? 


ACTION ITEMS
 

MR. GRIFFON: Do you want me to read through 


all these actions? 


MR. HINNEFELD: Yeah. 


MR. GRIFFON: In starting I listed all the 


actions with the findings so 4.1-1 I have the 


seven actions. And I read through these 


already, but I’ll go through them again. 


NIOSH to review assumptions on 


enrichment level. Two is NIOSH to provide 


references regarding enrichment levels. 


Originally I had SC&A but now we know that 


it’s the Bogar 1986 reference. So I guess 


we’re going to be able to track that back from 


DOE. Was that the idea, Stu? 


MR. HINNEFELD: We should be, that should be 


easily findable, I say naively. 


MR. GRIFFON: So NIOSH to recover this 


reference is what I changed that to. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

369 

Three, NIOSH to provide sample DR to 


demonstrate approach for doing internal DR for 


uranium. And Mark, you said you may have one 


of these already but adjust it if you need to 


or whatever and make sure we know where it is. 


Four, NIOSH to examine whether 


approach is appropriate for all members of the 


class parentheses, is there a subset of 


workers or areas where a different assumption 


should be made? That’s with regard to 


enrichment levels. 


Five, NIOSH to review the total 


production numbers for uranium, paren, provide 


written responses clarifying differences in 


the numbers in the TBD versus other 


documentation. 


Six, NIOSH to provide claim numbers of 


workers that worked in blending areas or high 


enrichment areas. 


MR. CHEW: Worked in what areas? 


MR. GRIFFON: Blending areas I think is what 


Mark, or other high enrichment areas. 


And seven, NIOSH will examine issue 


related to renal failure and effects on 


uranium excretion and on DR approach. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

370 

And then I’m on to 4.1-2, and I can 


send all, I’ve got all of these in matrix. I 


can send it out so if you were frantically 


typing. 4.1-2, NIOSH is attempting to recover 


laboratory procedures and QA reports from the 


early time period, ’54 through ’80. 


Two, NIOSH to post HIS-20 database. I 


put paren, with all identifiers, because I’ve 


been around this block before, on the O drive. 


Three, NIOSH to recover urinalysis 


logs and/or Health Physics reports that can be 


used to verify HIS-20 database data and post 


on the O drive. 


And on that one I said NIOSH to 


recover. I should say NIOSH will attempt to 


recover because I’m not sure they’re available 


as you said. Do you have a question on that? 


MR. MORRIS: I thought you were asking us to 


delegate the HIS-20. 


MR. GRIFFON: No. 


Four, NIOSH to compare selective cases 


with lung count data and urinalysis data. 


DR. MAKHIJANI: Would that include also --


MR. GRIFFON: I’m trying to remember what 


that meant. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

371 

DR. MAKHIJANI: I know what it --


MR. MORRIS: Let me tell you what my 


recollection of that was. We had a very small 


number of people with lung count, elevated 


lung count data, and those are the only people 


really that make sense to try to compare to 


urinalysis. 


MR. GRIFFON: Elevated lung count cases. 


I’ll put it in parentheses so I remember. 


Yeah, that was it. 


DR. MAKHIJANI: And are we going to compare 


also with air monitoring data or not? 


MR. MORRIS: We could, but I’m not sure it 


makes much, I would be surprised to find any 


really good results by that method. We can 


look. 


MR. GRIFFON: Since there weren’t, it didn’t 


come up before. I mean that would be new. 


DR. MAKHIJANI: So now is air not included? 


MR. GRIFFON: My sense is you don’t have air 


sampling data for uranium, right? I mean, you 


have it, but you haven’t compiled it yet. You 


haven’t compiled it yet, right, in any usable 


fashion. 


Four-point-one-dash-three -- I have 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

372 

two actions. NIOSH will provide coworker 


model along with all analytical files on the O 


drive. That’s the coworker model for the --


MR. MORRIS: Urine analysis as it becomes 


available. 


MR. GRIFFON: As it comes available, yeah. 


Two, NIOSH will follow up on 


individuals identified in the memo cited in 


the SC&A report. If any are claimants, NIOSH 


will assess the elevated urinalysis results. 


This is the three women that we just 


discussed, right? 


DR. MAKHIJANI: Yeah. 


MR. GRIFFON: And then 4.1-4 it says see 


actions in 4.1-1. So we kind of covered the 


same thing. 


Four-point-one-dash-five, NIOSH will 


provide update on RU feed and raffinate 


assumptions in the site profiles revision. So 


this is in your site profile revision. 


Including material flow information. 


Two is NIOSH will post thorium air 


sampling data, paren, gross alpha and Thorium230 data. 


I think I captured everything, but if 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

373 

I didn’t, somebody feel free to chime in. 


DR. MAKHIJANI: We’re following along with 


you. 


MR. GRIFFON: Four-point-one-dash-six I 


don’t have any action on that currently. Now, 


at this point I don’t know that that means 


that item’s closed out, but we just don’t have 


an action right now. 


Four-point-two-dash-one, NIOSH will 


provide recently recovered data on the --


DR. ZIEMER: Four-one-six we said was, would 


be covered by the action in 4.1-5. 


MR. GRIFFON: Did we? Okay. 


DR. ZIEMER: At least that’s the note I 


have. 


MR. GRIFFON: So see 4.1-5. 


DR. ZIEMER: Four-one-five is covered by 


4.1-6. 


MR. GRIFFON: Four-point-two-dash-one, NIOSH 


will provide recently recovered data on the O 


drive. And that’s, paren, radon breath, 


thorium air, radium-slash-thorium activity 


ratio data, but you may have already given us 


that. I’m not sure. I just added that in. 


But it’s in there if we didn’t get it already. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

374 

The second one, NIOSH will provide new 


model along with supporting analytical files, 


and that TBKS-0017-5 Internal Dose Section. 


Four-point-two-two, I don’t have 


anything for that. It may be that it --


DR. ZIEMER: It’s also covered by 4.1-5. 


MR. GRIFFON: See 4.1-5. 


DR. MAKHIJANI: There’s also the recovering 


the Gilbert Report, the Anigstein Report. 


MR. GRIFFON: I’ve got that coming up 


somewhere. Keep that, Arjun, if I missed it, 


but I think I’ve got it in a later action. 


Four-point-two-dash-three, NIOSH will 


provide Pinney data, I said, from the, that’s 


okay to reference her since it’s her report, 


right? Pinney data and reports on the O 


drive. The data and her reports if you have 


that. I think you have both, right? 


Two, NIOSH will provide updated model 


for the Environmental Section, TBKS-0017-4. 


Four-point-three-dash-one, NIOSH is 


revising the thorium model using air sampling 


data along with location, job and year. NIOSH 


will provide this model to the work group. 


MR. MORRIS: I think we could just refer you 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

375 

to that Battelle Report 6000 or 6001, I think. 


It’s in our --


MR. GRIFFON: So it’s the same Battelle 


model? It doesn’t even use the Fernald data 


in that model? 


MR. MORRIS: We’ll just put our air sample 


data in it. 


MR. GRIFFON: In that model, okay. 


MR. MORRIS: Yeah, but we did not change the 


model. 


MR. GRIFFON: So the model’s there, but the 


data we need to see, right. 


MR. MORRIS: So do you want to just 


(inaudible) the action and (inaudible) to the 


data. Is that right? 


MR. GRIFFON: I think so, yeah. 


MR. HINNEFELD: Which I think we covered 


previously. 


MR. GRIFFON: I thought it was adapting that 


model for Fernald, but you’re using the same 


exact model. 


MR. MORRIS: Exactly, I think we clarified 


how some of the coefficients were derived 


because it wasn’t obvious in their write up. 


MR. GRIFFON: Okay, is that in your TBD 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

376 

though? 


MR. MORRIS: It’s in our TBD draft, yes, but 


we didn’t change any numbers. 


MR. GRIFFON: So I guess there’s no action 


here on the model. 


MR. MORRIS: Right. 


MR. GRIFFON: Then I have NIOSH will provide 


analytical data used for the model on the O 


drive. Okay, so that’s the one that stays. 


All right, 4.3-2, I say, see 4.3-1. 


Four-point-three-dash-three, NIOSH 


will provide as part of the model mentioned in 


the response to 4.3-1 the decision criteria to 


be used to determine how workers will be 


placed into the model. This was from Stu’s 


comment. So it’s the decision criteria for 


how you’re going to place workers, and that 


may be rolled into your TBD or wherever it 


falls. I don’t care. 


Four-point-three-dash-four, see 


previous actions. 


Four-point-three-dash-five, see 


previous actions. 


Four-point-three-dash-six, NIOSH will 


post thorium in vivo data. I have ’68 to xx. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

377 

I wasn’t sure --


MR. MORRIS: ‘Eighty-eight. 


MR. GRIFFON: To ’88, yeah, I couldn’t 


remember. 


MR. MORRIS: We may have already done that. 


MR. GRIFFON: Okay, if it’s done then you 


can just report back and say it’s there. 


Yeah, NIOSH will post thorium in vivo data and 


associated model is what I put. You have a 


coworker model with that, right? 


MR. HINNEFELD: The coworker model will come 


out. 


MR. MORRIS: That’s almost done. It just 


hasn’t been approved yet. 


MR. GRIFFON: And two, NIOSH will review Oak 


Ridge audit report regarding findings related 


to the quality of in vivo data. This was from 


the comment that Sandy made about the audits 


that mentioned the concerns over the in vivo 


data. And I think it’s in the petition, 


right? So you can find that referenced audit 


report. 


Four-point-three-dash-seven and eight, 


I don’t have anything on those two. 


Arjun, I might have lost that one with 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

378 

the Gilbert, but anyway, 4.3-9, NIOSH will 


post revised model which includes the Battelle 


model for ingestion. So maybe it’s the same ­

-


DR. MAKHIJANI: It’s all the same thing. 


MR. GRIFFON: It is the Battelle model. So 


we have the Battelle model which, I guess, 


SC&A needs to look because this is new 


information for us. 


DR. MAKHIJANI: We have been assigned to 


review that. 


MR. GRIFFON: Under another task, yeah. 


Four-point-three-dash-ten, NIOSH will 


attempt to recover raw data, logbooks, Health 


Physics reports, air samples, survey reports, 


et cetera, which may be used for a comparison 


against thorium air sampling datasets. This 


is the attempt to validate against the raw 


basically is what this is asking. 


DR. MAKHIJANI: Mark, I also have recovery 


of the logbooks for the individual who took 


the air samples. 


MR. GRIFFON: So this individual cited, I 


guess, I was kind of including that in that 


same action. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

379 

DR. MAKHIJANI: Since it came up 


specifically regarding the --


MR. GRIFFON: Can we cite his name here? 


Wasn’t his name in the --


MR. RICH: No, it was blanked out. 


MR. GRIFFON: Oh, it was blanked out, okay. 


NIOSH will attempt to recover --


DR. BEHLING: We can identify --


MR. RICH: Everybody knows who it is. 

MR. CHEW: I-H’s logbook, right? 

MR. RICH: Or some other logbook associated 

with --

MR. GRIFFON: Well, that was in my first 


action was any log, and then specifically his 


log, right? His logs. 


Four-point-four-dash-one, NIOSH 


intends on using urinalysis data for the 


coworker model. No further actions. That was 


a comment there more than an action. 


Four-point-four-dash-two, NIOSH will 


provide coworker model developed from in vivo 


data and the underlying assumptions for the 


model. I think that might be duplicative to 


what I said before. 


Four-point-four-dash-three, NIOSH will 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

380 

review the selection criteria procedures and 


post to the O drive. This was basically if 


you can find how these people were selected 


for the monitoring program, any documentation 


to support your belief that the highest 


exposed were monitored. 


And the next, 4.4-4, no further action 


is what I have. 


Four-point-four-dash-five, NIOSH will 


re-evaluate cases which may be affected by, 


oh, that’s just overall statement that --


Four-point-five-dash-one, NIOSH will 


attempt to recover QA inter comparison studies 


or internal studies, paren, Herb Parker Report 


and other reports. 


Four-point-five-dash-two, I have 


nothing on. 


Four-point-five-dash-three, NIOSH will 


examine whether an adjustment is necessary to 


account for this potential unmonitored dose. 


That’s the beta contamination. 


Four-point-five-dash-four, NIOSH will 


provide the neutron survey data along with the 


methods used in the survey. That’s from your, 


relevant to your presentation. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

381 

And 4.5-5, it says, see action on 4.1­

3. That’s the three women we mentioned in 


4.1-3. 


 MR. CLAWSON: Mark, I can’t remember where 


we had it. Isn’t that Baker Report a 1985 


report? 


MR. HINNEFELD: Gilbert. 


 MR. CLAWSON: Gilbert Report. 


MR. GRIFFON: I missed that somehow. 


MR. HINNEFELD: The Gilbert Report and the 


Westinghouse Transition Report. 


MR. GRIFFON: And the Tiger Team. 


MR. HINNEFELD: Yeah, Tiger Teams were 


later, but, yeah, the same thing with Tiger 


Teams. 


MR. GRIFFON: Where did you have that, 


Arjun? 


DR. MAKHIJANI: I didn’t --


MR. HINNEFELD: Oh, you know what? I had 


that around 4.2-1 


MR. GRIFFON: I’m sorry. I’m not finished. 


I have other general action items. That’s 


where I’ve got that one. 


MR. CHEW: Stu, your recollection of the 


Gilbert Report came out sort of right at the 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

382 

transition between National Lead and 


Westinghouse? 


MR. HINNEFELD: I want to say it may have 


come out in ’84. I think it may have come out 


before the decision to rebid the contract. 


The contract was rebid and awarded in December 


of ’85. 


DR. MAKHIJANI: There may be an excerpt from 


that in Hans’ report. It’s dated February, it 


looks like an evaluation. 


DR. BEHLING: I may have to --


MR. GRIFFON: Here’s my other general action 


item before we lose, you know, people have got 


to catch planes. I couldn’t fit them into the 


matrix really, so there are five other general 


action items. 


One, NIOSH will post all interview 


transcripts conducted in support of this 


review. Just something that came up earlier. 


Two, NIOSH will review the Tiger Team, 


Gilbert Reports and Westinghouse Transition 


Report to assure that all findings related to 


the NLO operation of the Fernald plant did not 


affect NIOSH’s ability to reconstruct dose 


parameters and includes reviewing the data 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

383 

integrity. 


Three, NIOSH will follow up on whether 


other groups or agencies did any offsite 


monitoring at Fernald. And it says, paren, 


contact John Burn to determine this? 


MR. MORRIS: Well, John ran an extensive 


monitoring program over the last ten years I 


think, ten years, 15 years maybe. 


MR. GRIFFON: Stu said he might have 


information regarding --


MR. HINNEFELD: He should know if there’s 


another agency monitoring. He should know 


that. 


MR. MORRIS: So the goal is inter-


comparisons to other --


MR. HINNEFELD: No, actually, the goal is to 


find out where there other agencies monitoring 


in the vicinity, taking some air or whatever 


in the vicinity. I think John would know 


about those. 


MR. MORRIS: I guess I’m not sure what the 


goal of that is. 


MR. GRIFFON: To what end? I think it was 


brought up, the petitioner or you brought it 


up. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

384

 MR. CLAWSON: Well, I brought it up because 


one of the things was is that gives us a good 


opportunity to somewhat kind of check our air 


data or whatever for the outside. Granted 


that they may have been down a ways or 


whatever, but it just kind of gives us a 


little better of a check and balance. 


MR. GRIFFON: A check on DOE’s data to see 


if it’s consistent for the use. 


MR. MORRIS: Can we move that to the TBD 


issues instead of the SEC issues? 


MR. HINNEFELD: We have to do them anyway. 


MR. MORRIS: We’ve got to do them anyway, 


but the timeliness of the SEC petition is what 


I’m focused on. 


MR. GRIFFON: I’m not sure if it’s a low, I 


mean, it might be a lower priority than some 


of the other ones. 


 MR. CLAWSON: Well, it’s just kind of a 


check and balance. So I don’t see an issue 


with that unless you do, Hans, or --


DR. BEHLING: We all agree it’s not an SEC 


issue, we can certainly shift it from here to 


the TBD. 


DR. MAKHIJANI: Do we have any other QA 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

385 

documentation on the air sampling independent? 


MR. HINNEFELD: I’m pretty sure there could 


be some produced in later years. Now the air 


sampling started before I did I believe. I 


think there were a few boundary station 


samplers. You’re talking about Barmelle* air 


sampling or are you talking the other air 


sampling? 


DR. MAKHIJANI: (Inaudible). 


MR. HINNEFELD: Oh, I don’t know. Was that 


in one of our actions? I don’t know. 


MR. GRIFFON: No, it wasn’t in the actions. 


DR. MAKHIJANI: Because this might provide 


some kind of checks from some periods. 


DR. ZIEMER: I have visited so many labs 


over the years, I (inaudible). 


MR. GRIFFON: I think it might be useful at 


least to keep a high priority to identify if 


other things were done, not necessarily to 


then find all that data and start working with 


it, but at least identify are there other 


studies at the time. And then come back and 


report and say, yeah, we found this. What do 


you want us to do with it? 


MR. CHEW: You don’t want this analyzed? 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

386 

MR. GRIFFON: No, don’t waste a lot of time 


with it yet. Just find out what’s there and 


characterize it. 


DR. MAKHIJANI: Yeah, I think that’s good. 


DR. ZIEMER: Wait until later to waste time. 


MR. GRIFFON: We have plenty of time to 


waste now. 


Anyway, NIOSH should follow up on 


committee formed to reconstruct thorium 


operational history. And this is the basis 


for one of the sections in the Dolan and Hill 


report, so when I say follow up, I mean did 


they have a separate report? What was on that 


committee? I think that needs to be followed 


up on and fleshed out a little bit. It seems 


to be an important piece that we might 


interested in. I know that we have, we’re 


relying on the thorium air data, but the 


thorium processes might be very important in 


terms of what went on at what time and who was 


there. 


MR. MORRIS: Could be, but we’ve got it 


fairly really well documented thorium 


processing stream at this point. 


MR. GRIFFON: Well, that was one thing. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

387 

This mentioned, this committee --


 MR. CLAWSON: Well, I think that’s what Hans 


brought up that --


MR. GRIFFON: -- if it’s a dead end, then 


it’s a dead end. 


 MR. CLAWSON: -- lay it out in different 


liters, whatever. 


DR. MAKHIJANI: If they feel they have 


complete documentation now, I mean, for me it 


would be a higher priority to see that 


documentation rather than try and find what 


some committee did. 


MR. GRIFFON: I agree. 


And last is NIOSH should follow up on 


doses assigned in the beginning years, ’83 


through ’85, of the use of the TLD badge and 


what data was recorded likely limited to the 


skin dose correction issue is what I’ve got in 


parentheses. 


DR. MAKHIJANI: You’re so thorough. You’ve 


got everything. Everything I had anyway. 


 DR. WADE: Okay, Mr. Chairman, anything 


else? 


 MR. CLAWSON: No, I just want to say I 


appreciate everybody, their professionalism 

1 

2 

3 

4 

5 

388 

and it’s been fun. 


 DR. WADE: Thank you for your service, all 


of you. Thank you very much. 


(Whereupon, the working group meeting 


concluded at 5:17 p.m.) 

______________________________ 

389 

1 CERTIFICATE OF COURT REPORTER 


STATE OF GEORGIA 


COUNTY OF FULTON 


 I, Steven Ray Green, Certified Merit Court 


Reporter, do hereby certify that I reported the 


above and foregoing on the day of August 8, 


2007; and it is a true and accurate transcript 


of the testimony captioned herein. 


 I further certify that I am neither kin 


nor counsel to any of the parties herein, nor 


have any interest in the cause named herein. 


 WITNESS my hand and official seal this the 


17th day of October, 2007. 


STEVEN RAY GREEN, CCR 


CERTIFIED MERIT COURT REPORTER 


CERTIFICATE NUMBER: A-2102